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Schwaben Policy

Schwaben Policies & Procedures
For Schwaben Capital Group Limited April 14, 2010

INTRODUCTION

The Schwaben Capital Group Limited (“Schwaben”) Policies & Procedures Manual is designed to outline Schwaben’s policies, procedures, monitoring and control practices relating to the management of investment funds for our Clients. These practices have been created to ensure that the highest standards of governance are met in the ongoing management of all investment funds. They are designed to ensure that we are operating in the best interests of all our Clients by avoiding any conflict, or potential conflict, between the policies and objectives of our Clients and those of Schwaben.

The Schwaben Capital Group Limited (“Schwaben”) Policies & Procedures Manual is designed to outline Schwaben’s policies, procedures, monitoring and control practices relating to the management of investment funds for our Clients.

These practices have been created to ensure that the highest standards of governance are met in the ongoing management of all investment funds. They are designed to ensure that we are operating in the best interests of all our Clients by avoiding any conflict, or potential conflict, between the policies and objectives of our Clients and those of Schwaben.

Schwaben seeks to meet its duty of care, due diligence and compliance with the law, codes and standards of professional conduct of industry-related governing bodies (e.g., the Ontario Securities Commission, the Toronto Stock Exchange, the U.S. Securities and Exchange Commission, CFA Institute, IFIC, etc.), accepted industry practice and fair dealing. It is a requirement of employment applied to all Associates of Schwaben and other Access Personnel to be knowledgeable of, and to act in compliance with, legal and regulatory requirements as they relate to their responsibilities and their actions on behalf of Schwaben. To the extent that any Associate lacks such knowledge or has any doubts relating to any issues or situations that may arise, it is the responsibility of the Associate and Access Personnel to seek the assistance of the Compliance Officer.

The spirit, as well as the letter, of this Manual must be observed. For greater clarity observance of the precise wording of the principles, procedures and rules does not suffice where there is a clear breach of the spirit. The highest level of personal integrity is expected of all Associates. This Manual applies to all Schwaben Associates and other Access Personnel.

To obtain a complete copy of the Schwaben Policy and Procedures, please contact us at Schwaben Capital Group Limited.