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St. James INVESTMENT ADVISORSPORTFOLIOAGGRESSIVE - GROWTH - MODERATE - CONSERVATIVE

ST. JAMES INVESTMENT ADVISORS1INVESTMENT objectivesSt. James offers a choice of asset allocation portfolios to serve different investment goals.We offer four portfolios for different types of investors which are managed with a consistent process.We offer an Aggressive Portfolio, Growth Portfolio, Moderate Portfolio, or Conservative Portfolio.Our portfolios seek to provide absolute return through a combinationof capital appreciation and income.An asset allocation portfolio invests in a diversified portfolio to perform with less volatility than individual asset classes.Allocation decisions are made based on our view of overall market risk and careful examination of individual security valuation across multiple asset classes.

ST. JAMES INVESTMENT ADVISORS2INVESTMENT strategiesAGGRESSIVEPORTFOLIOAGGRESSIVESt. James Aggressive PortfolioThe St. James Aggressive Portfolio seeks to provide totalreturn through a combination of very aggressive growth andsome income. This is a “flexible” portfolio, meaning that investments are allocated among equities, bonds, absolute return investments, alternative investments, and cash, depending on our view of each asset class. The Very Aggressive risk approach may appeal to investors wanting aggressive long-term capital appreciation.The investment guidelines of the St. James Aggressive Portfolio allow some allocation of electronically traded funds, mutual funds, equity securities, select fixed income securities, alternative investment mutual funds and/or other instruments.

ST. JAMES INVESTMENT ADVISORS3INVESTMENT strategiesThe St. James Growth Portfolio seeks to provide total return through a combination of aggressive growth and income. This is a “flexible” portfolio meaning that investments are allocated among equities, bonds, absolute return investments, alternative investmentsand cash, depending on our view of each asset class.The Aggressive risk approach may appeal to investors wantinglong-term capital appreciation with modest income.The investment guidelines of the St. James Growth Portfolio allow some allocation to equity securities, mutual funds, electronictraded funds, closed end funds, select fixed income securities,alternative investment mutual funds and /or other instruments.St.James Growth Portfolio

ST. JAMES INVESTMENT ADVISORS4INVESTMENT strategiesThe St. James Moderate Portfolio seeks to provide total returnthrough a combination of moderate growth and income. Thisis a “flexible” portfolio, meaning that investments are allocatedamong equities, bonds, absolute return investments, alternativeinvestments and cash, depending on our view of each asset class.The Balanced risk approach may appeal to invesors wantinglong-term capital appreciation with modest income.The investment guidelines of the St. James Moderate Portfolioallow some allocation to equity securities, mutual funds, electronictraded funds, closed end funds, select fixed income securities, alternative investment mutual funds and/or other instruments.MODERATATAEPORTFOLIOMODERATESt.James Moderate Portfolio

ST. JAMES INVESTMENT ADVISORS5INVESTMENT strategiesThe St. James Conservative Portfolioseeks to provide a positiveabsolute return through a combination of capital appreciation and income.This is a “flexible” portfolio, meaning that investments are allocatedamong equities, bonds, absolute return investments, alternativeinvestments and cash, depending on our view of each asset class. TheSt. James Conservative Portfolio emphasizes the protection of capital underall market conditions.The Conservative Risk approachmay appeal to investors concernedabout the relative volatility of future market returns.The investment guidelines of the St. James ConservativePortfolio allow some allocation to equity securities, mutualfunds, electronic traded funds, closed end funds, select fixed income securities, alternative investment mutual fundsand/or other instruments.CONSERVRVRAVAVTATAIVECONSERVATIVEPORTFOLIOSt.James Conservative Portfolio

ST. JAMES INVESTMENT ADVISORS6INVESTMENT philosophy"Committed to Value Investing" O ur rem o t e location s e ts u s apa r t from t he emotions and short-term views of Wall Street. This physical and psychological distanc e allows u s to patient l y a nd t horoughly i n s pect and s elect e ach i nve stment . Our goal is t o maxim i ze long-term total return on capital. We also realize that prudent investors want to minimize risk and protect their assets. Therefore, we employ a value approach to investing.The philosophy that guides the management of our equity and balanced portfolios is built on traditional principles. We main -tain a long-term focus, conduct our own research and employ a rigorous price discipline. Our decision-making process takes full ad v a n tage of i n dividual i n sights with i n a part ners h i porient ed culture. These factors drive the ac hie vement of t he competitive returns we seek for our clients and their portfolios.Our small "family" of portfolios is designed to offer a range of investment options for investors with different objectives and temperaments. These range from aggressive portfolios to conservative portfolios. There are differences in portfoliosize, portfolio concentration, volatility, and tax sensitivity. "We eat our own cooking." Some of our investment professionals have a majority of their families’ liquid net worth invested in our portfolios.This does not guarantee that the portfolios will go up, but itmeans that we win or lose together and that clients definitely haveour attention.

ST. JAMES INVESTMENT ADVISORS7WE ARE ABSOLUTE RETURN INVESTORS AND EACH INVESTMENT MUST MEET OUR STRICT FUNDAMENTAL RESEARCH AND MACROECONOMIC CRITERIA, NOT JUST OFFER OPPORTUNITYRELATIVE TO OTHER ALTERNATIVES.ABSOLUTE RETURN INVESTORS BUY ASSETS THAT ARE OUT OF FAVOR BECAUSE THEY ARE CHEAP. RELATIVE RETURN INVESTORS BUY ASSETS THAT ARE POPULAR, WHICH MEANS THATTHEY ARE ALREADY FULLY PRICED.TRYING TO KEEP PACE WITH THE MARKET IN ALL ENVIRONMENTS PROMOTES POORDECISIONS AND INCREASES THE CHANCES OF MAKING MISTAKES.FOCUS ON THE PROCESS AND DECISIONS – LET THE OUTCOMES TAKE CARE OF THEMSELVES.A VALUE INVESTOR WITH AN ABSOLUTE RETURN MINDSET MAY OUTPERFORM BY PROTECTINGCAPITAL IN DOWN MARKETS AND PRODUCING POSITIVE RETURNS IN UP MARKETS.BE PATIENT (AND NOT AFRAID TO HOLD CASH).BE UNCONSTRAINED.INSIST UPON MARGIN OF SAFETY.WE DO NOT FOLLOW THE CROWD. WE ARE INDEPENDENT IN OUR DECISION MAKING AND WE ARE OFTEN VIEWED AS CONTRARIAN IN OUR STRATEGY AND EXECUTION.PRINCIPLES OF INVESTMENTSINVESTMENT philosophy

ST. JAMES INVESTMENT ADVISORS8INVESTMENT philosophyWe think “ benchmark risk” is part of investment life. Our firm’s goal is to earn solid absolute investment returns over long periods of time without exposing our clients’ capital to unduerisk. We do not think about any particular index when we makeinvestment decisions. We also believe that cash is sometimes the most attactive investment. We know that this approach causesheadaches for some of our favorite consultants, but we thinkflexibility and common sense will continue to serve our clientswell over the years. Lastly, we discourage short-term speculators and market timersfrom joining us and will communicate with our investmentpartners as candidly as possible.

ST. JAMES INVESTMENT ADVISORS9Absolute Return Mindset - Absolute return investors buy assets that are out of favor because they are cheap. Relative return investors buy assetsthat are popular, which means that they are already fully priced. Further,trying to keep pace with the market in all environments promotes poordecisions and increases the chances of making mistakes. As one cannotspend relative performance, absolute returns are the only returns that matter.Independent Research -Original research is at the heart of each invest-ment, forming a well-founded thesis that looks at least three years ahead.Because we have independently built the case for our ideas, we have theconfidence to invest in out-of-favor areas and to hold our ground whenshort-term sentiment runs the other way. In our experience, periods ofgreat pessimism often generate the best investment bargains.Long-Term Orientation - Years of investing have taught us that investorperceptions of an investment fluctuate much more widely than underlying fundamentals. As a result, we are habitually focused on thelong-term and continually ask ourselves: “based on what we know today,how would we invest an all-cash portfolio if we could not trade for threeto five years?” This exercise forces us to re-evaluate our portfolio holdingswithin an ever-changing market environment, and to reaffirm our rationalefor long-term appreciation.Strict Price Discipline - A low entry price for each security position is a keydriver of future returns. First, a low price incorporates low investor expectations that often serve as a buffer against the risk of decline. Second, investing at a low valuation creates greater potential forcapital appreciation.

ST. JAMES INVESTMENT ADVISORS10You should carefully consider the portfolio’s investment objectives, risks, charges and St. James INVESTMENT ADVISORSSt. James Investment Advisors is an independent, fee-only, U.S. Securitiesand Exchange Commission registered investment advisory firm, provid-ing customized portfolio management services to individuals and their financial advisors.Our investment methodology blends a combination of fundamental analysis, discipline and patience with the goal of creating long-term returns based on the time-proven principles of value investing.We are professional portfolio managers Committed to Value Investing and our sole focus as a firm is to manage private investment accounts for individuals and their financial advisors throughout the United States.