Integra Capital Group - Investment Approach

Management: We believe that, to the extent possible, local management of investment assets is preferable to third-party long-distance management. We believe that directly working with the advisor(s) that manage your wealth
provides a much higher level of accountability and transparency.

Investments: We believe in having the maximum number of high quality investment choices available to us. That said, we are biased against third-party management (i.e. mutual funds) except when absolutely necessary (e.g. commodities and managed futures funds). The overwhelming majority of our investment options will be both equity and fixed income Exchange Traded Funds (ETFs), individual stocks and bonds, and cash equivalent investments, keeping fees to a minimum while keeping transparency to a maximum.

Active vs. Passive: We believe in using diversified investment vehicles in an active way. Our focus will be on primarily using ETFs for our core investments. This will allow us to overweight sectors or strategies we believe have more
current upside potential and underweight (or, in some cases, be opposite) those sectors or strategies we feel will underperform.

Risk: We believe that managing risk is extremely critical to the overall effectiveness of any investment program. There is a trade-off between how much risk a Client can afford to take, how much risk a Client needs to take, and how much risk a Client can mentally accept. Our consultative approach (and lack of conflict when it comes to compensation) guides us through determining the balance between these three different aspects of risk measurement.

Commissions vs. Fees: When it comes to investing we believe that commissions inherently represent a conflict of interest between the Advisor and the Client because they are the result of transactions rather than advice. Our focus is on providing advice that is relevant to a Client’s goals, not in generating commissions.

Independence: We believe that Clients are best served by truly independent investment advice derived from truly independent research. This means we believe that the advisors you work with should not be influenced by selling the “in-house” product and the company should not be engaged in any conflicting activities like investment banking.