Dealing in Assets by Connected Persons Policy

There is no prohibition with regard to dealing in the assets of the Fund by the Management Company, the Investment Manager or entities related to the Management Company or the Investment Manager: Provided always that the transaction is effected on normal commercial terms negotiated at arm’s length and is in the best interests of Shareholders.

The Management Company’s and the Investment Manager’s principals, affiliates and employees act in similar capacities (as portfolio manager and otherwise) of other investment companies, mutual funds and accounts that are engaged in activities similar to those of the Fund. To a limited extent, these funds and accounts may invest and divest side-by-side with the Company and therefore may compete for the same securities and transactions as the Company. The existence and identity of operations of the foregoing funds and accounts create a conflict of interest for the Management Company and the Investment Manager. The investment information, methods and strategies that the Investment Manager utilises in managing and advising, respectively, the account of the Fund may be utilised by the Investment Manager, its principals, affiliates and employees in managing investments for other customer accounts. But the Investment Manager, its principals, affiliates and employees will allocate investment information, methods and strategies on a basis which, in their good faith judgement, is fair and equitable in light of the Fund’s available capital and investment policies.

The Management Company, the Investment Manager, their principals, affiliates and employees shall devote only so much time and attention to the business and affairs of the Fund as they in their sole discretion may deem reasonably necessary for the purposes of the Fund, which shall not require a full-time commitment.

The Management Company, the Investment Manager, their principals, affiliates and employees may engage in, invest in, participate in or otherwise enter into other business ventures of any kind, nature or description, alone or with others, including, without limitation, the management of or investment in other investment entities or vehicles or securities, and neither the Fund nor any Shareholder shall have any right in or to any such activities or the income or profits derived there from. The Management Company, the Investment Manager, their principals, affiliates and employees may invest for their own accounts, including in securities and transactions which are the same as or different from those traded or held by the Fund.