|Tortoise acts as a fiduciary in every client relationship.
Tortoise is a fee-only provider. The only payments we receive are from our clients and are specified in the client contract. We do not accept commissions, soft dollars, 12(b)(1) fees or any other form of third-party payment. Tortoise is entirely independent. We have no house product. We do not engage in principal transactions. When you work with Tortoise, you will know precisely what you pay us and that our fees are not affected by investment selection or other relationships.
| Tortoise manages its clients’ accounts on a discretionary basis, pursuant to written investment guidelines specified in the client contract.
Client accounts are registered separately in the clients’ names and are generally custodied at Fidelity Investments, except for employment-based retirement accounts (i.e. 401(k) accounts) which remain with the custodian specified in the employer’s plan. Client assets are never commingled or held in Tortoise’s custody.