Conflicts of Interest Policy 

Background

The Investment Research Policy ("IRP") of Clear Capital Limited ("Clear Capital") applies to all investment research which is published or distributed to Clear Capital's clients. The purpose of the IRP is to set out Clear Capital's policy for managing any conflicts of interest which might affect the impartiality of its investment research. All employees are required to comply with Clear Capital's IRP.  In the event of any changes to the IRP, a copy of the previous version of the IRP must be retained for at least three years after it ceases to have effect.

No analyst may prepare research which is intended firstly for internal use for Clear Capital's own advantage, and then for later publication to clients.

The IRP must be made available to any person in writing, on request.  In practice, the IRP is accessible through a link on Clear Capital's website.

The IRP applies to all types of investment research issued by Clear Capital.

Policies

No employee of Clear Capital may carry out any personal account dealing which could create a conflict of interest which might affect the impartiality of Clear Capital' investment research.  Any proposed personal account dealing by employees is subject to pre-approval by a senior employee of Clear Capital and no dealing which could create a conflict of interest between the employees of Clear Capital and its customers will be permitted.  In addition, a prohibited list of securities is maintained.  Note that Clear Capital itself does not hold securities on its own account.

All of Clear Capital's investment analysts are supervised by senior employees of Clear Capital.

The remuneration structure for investment analysts is not linked in any way to dealing or other activities which customers carry out as a result of the independent research provided by Clear Capital.

Clear Capital's investment analysts are not permitted to be involved in any activities which could be seen as conflicting with Clear Capital's provision of investment research.  Any outside business activities of employees are subject to prior approval by a senior employee.

No inducements offered by issuers, or others with a material interest in the subject matter of investment research, may be accepted by investment analysts or senior employees of Clear Capital.

No one outside Clear Capital may comment on draft investment research before publication.

The timing and manner of publication and distribution of investment research and of the communication of its substance must be approved in advance by a senior employee of Clear Capital.

Certain disclosures may be included in the research where appropriate, for example for legal reasons.

All Investment research issued by Clear Capital must be independent, impartial and objective.

Before being issued, all research documents must be approved and signed-off by a senior analyst.

Clear Capital issues research to Market Counterparties and Intermediate Customers only.

Clear Capital does not conduct any investment business with or for its clients (other than the provision of research) or on its own account.

No individuals within Clear Capital may have any responsibilities that conflict with the interests of the clients to whom the investment research is published or distributed.  Clear Capital does not, for example, have any involvement in raising capital for corporate clients.

The remuneration of Clear Capital's investment analysts is structured so as not to create any incentive which is inconsistent with the provision of an impartial assessment of the subject matter of investment research by the analyst.

Remuneration is not linked to a specific transaction, or to recommendations contained in investment research, although it may be linked to the general profits of Clear Capital.

Clear Capital's investment analysts must not carry out any activities which could be seen as inconsistent with providing an impartial assessment of the value or prospects of the relevant investments.

Clear Capital does not carry out any corporate finance business, and does not sell or trade securities.  Nor does Clear Capital represent issuers of investments.

Clear Capital's investment analysts and other employees are prohibited from offering or accepting any inducement to provide favourable investment research.  Only an investment analyst employed by Clear Capital may approve the content of investment research before publication; and no person outside Clear Capital or any employee of Clear Capital other than an investment analyst may view research before its publication for verification of factual information in the investment research.

Clear Capital's policy and procedures require investment research to be published or distributed to its clients in an appropriate manner.

Investment research must be published or distributed only through its usual channels, as set out in the policy; and no employee may communicate the substance of any investment research, except as set out in the policy.

November, 2006