Policy and procedures regarding inducements

1. Introduction

A portfolio management company may receive incentives (i.e. inducements) from the managers of the funds it invests in its clients' portfolios. These incentives may take the form of a gift, a rebate or a commission. These practices do not occur in the trackers industry (i.e. a category of financial instruments exclusively used by the company). Moreover, the company's policy is not to accept inducements.

2. Policy

The following is the company's sole policy on inducements.

1. Never inducements
   The company has a policy of never accepting inducements. The company prefers to be independent of any fund and to communicate simple, understandable and transparent rates and cost structures to its clients. The company finds inducements to be an abomination to the client and a source of conflict of interest.

3. Procedures

3.1. Never inducements

A portfolio management company that receives overpayments is required to return them. Since the company does not receive any overpayments, there is no specific procedure for doing so.

3.2. Monitoring compliance with policies and procedures

The Compliance Officer is responsible for enforcing this policy and implementing these procedures within the company.