Best Execution Policy Disclosure Statement

This document describes the Order Execution Policy of the Investment Manager in respect of the steps taken to obtain the best possible execution outcome when buying and selling securities on behalf of its clients.

Origin and purpuse of order execution policy
Under the direction of the European Community, (Markets in Financial Instruments Directive – MiFID), investment managers are now required to define their Order Execution Policy and communicate this to their clients.

Order Execution – Obtaining the best overall result
In executing orders for client portfolios, the Investment Manager takes all reasonable steps to obtain the best possible result, taking into account the following Execution Factors: price; cost or any other consideration relevant to the execution of the order.

Price will normally merit the highest relative importance in obtaining the best possible result. However in some circumstances, for some clients, financial instruments or markets, it may be appropriately determined that other execution factors are more important than price in obtaining the best possible execution result.

The Investment Manager will determine the relative importance of the execution factors by using its commercial judgment and experience in light of the market information available and taking into account the characteristics of the order, the financial instruments that are the subject of that order, the client and the execution venues to which that order can be directed.

Single venue transactions
In some cases the Best Execution obligation technically applies but, because of the nature of the order given by the Company, or of the transaction, the obligation is, in effect, satisfied. For example, where the nature of the transaction results in there being only one venue, therefore, the only pricing consideration is timing of execution. Such a situation precludes the use of comparable prices.

Monitoring and review
The Investment Manager will monitor the effectiveness of its order execution arrangements and order execution policy in order to identify and, where appropriate, correct any deficiencies. The Investment Manager will assess on a regular basis whether the execution venues referred to in this execution policy, and the brokers and dealers to whom orders are transmitted, facilitate the achievement of best execution on a consistent basis or whether changes need to be made to the execution arrangements.

The Investment Manager will review its execution policy regularly and in any event whenever a material change occurs that affects its ability to obtain the best possible result for its clients. The Investment Manager shall notify the Company in the event that there are any material changes to its execution policy following such review.