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Fairness Policy

SCHWABEN CAPITAL GROUP LIMITED

PROCEDURES DESIGNED TO ENSURE FAIRNESS IN THE ALLOCATION OF INVESTMENT OPPORTUNITIES
March 8, 2010

Schwaben Capital Group Limited (“Schwaben”) is required by law to maintain standards directed to ensuring fairness in the allocation of investment opportunities among its clients and to furnish a copy of its established policies to each client.

When orders for more than one account are entered as a combined order, and transactions are executed at varying prices, Schwaben will endeavour to treat all clients on a basis that is fair and reasonable in the context of the nature of the particular transaction and the transaction costs. This may include calculating a weighted average execution price and commission to be attributed to all accounts having orders included in the combined order. For greater certainty, when trades are bunched or blocked, the policy of Schwaben is to allocate the commissions amongst clients on a pro rata basis.

The principal determination used by Schwaben in allocating investment opportunities amongst its clients is the suitability of purchase and sale transactions as determined by the unique circumstances and needs of each client as set out in the Statement of Objectives and Investment Policy or other document containing the investment objectives and policy established for the client’s account, as revised from time to time. Schwaben’s policy is that no single account or type of account will receive preference in the allocation of investment opportunities.

When orders for more than one account are entered as a combined order and less than the total order is executed as a block, Schwaben will generally attempt to make pro-rata allocations on the basis of order size. Schwaben will also take into consideration the proportion of the portfolio (or portfolio section) that the security represents, the weight of the industry or security type in the portfolio (or portfolio section) and the cash reserve position in the portfolio (or portfolio section).

When orders for more than one account are entered as a combined order and the transactions are all executed at the same price, each client account will be given the same execution price.

Subject to market conditions and stock exchange procedures, Schwaben will use its best efforts to ensure that orders are processed and executed on a first-in, first-out basis.

When orders for an initial public offering are entered for more than one account and are completely or partially filled, Schwaben will attempt to the best of its ability to allocate the filled orders on a pro rata basis according to the proportion of the total of all orders submitted by Schwaben for that initial public offering and Schwaben will attempt to the best of its ability to calculate a weighted average execution price and commission to be attributed to all accounts included in orders for that initial public offering.

Schwaben will endeavour to ensure that orders and modifications or cancellations of orders are recorded and are time-stamped.

The foregoing procedures will be revised from time to time in keeping with changes in regulatory requirements and industry practices. In the event of any such revision, Schwaben will, as required, furnish a copy of the revised policies to each client.

People

Our business is all about people. clients as well as our employees. It is our employees that work to meet the financial services needs of our clients and it is our clients' trust in us that has allowed us to grow ou....

Investment

Our investment philosophy is value based. We seek long-term shareholder value in the companies we invests in. We invest in successful businesses rather then just stocks and bonds. We look for long-term shareholder v....

Capital

Over many years of experience, the partners of Schwaben have realized our client’s diverse needs. Successful entrepreneurs do not just have a need for asset management and financial and estate planning.