Common use of Execution of Brokerage Transactions Clause in Contracts

Execution of Brokerage Transactions. (when applicable). If requested, ADVISER will arrange for the execution of securities brokerage transactions for the Account through broker-dealers that ADVISER reasonably believes will provide “best execution”. In seeking „best execution”, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer‟s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although ADVISER will seek competitive commission rates, it may not necessarily obtain the lowest possible commission rates for Account transactions. Consistent with obtaining best execution, transactions for the Account may be effected through broker-dealers in return for research products and/or services which assist ADVISER in its investment decision making process. Such research generally will be used to service all of ADVISER‟s clients (including accounts that may not generate commissions used to pay for investment research), but brokerage commissions paid by CLIENT may be used to pay for research that is not used in managing the Account. The Account may pay to a broker-dealer a commission greater than another qualified broker-dealer might charge to effect the same transaction where ADVISER determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. Transactions for each client account generally will be effected independently, unless ADVISER decides to purchase or sell the same securities for several clients at approximately the same time. ADVISER may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among ADVISER‟s clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among ADVISER‟s clients in proportion to the purchase and sale orders placed for each client account on any given day. The CLIENT may direct ADVISER to use a particular broker-dealer to execute some or all transactions for the Account (subject to ADVISER‟s right to decline and/or terminate the engagement). In such event, CLIENT will negotiate terms and arrangements for the Account with that broker-dealer, and ADVISER will not seek better execution services or prices from other broker-dealers or be able to “batch” CLIENT transactions for execution through other broker-dealers with orders for other accounts managed by ADVISER. As a result, the CLIENT correspondingly acknowledges that such direction may cause the Account to incur higher commission or transaction costs than the Account would otherwise incur had the CLIENT determined to effect Account transactions through alternative arrangements that may be available through the ADVISER. In the event that the transactions for the Account are effected through a broker-dealer that refers investment management clients to ADVISER, the potential for conflict of interest may arise.

Execution of Brokerage Transactions. (when applicable). If requested, ADVISER will arrange for the execution of securities brokerage transactions for the Account through broker-dealers that ADVISER reasonably believes will provide “In seeking best execution”. In seeking „best execution”, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer‟s the Custodians’ services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although ADVISER we will seek competitive commission rates, it we may not necessarily obtain the lowest possible commission rates for Account transactions. Consistent with obtaining best execution, transactions for the Account may be effected through broker-dealers in return for research products and/or services which assist ADVISER in its investment decision making process. Such research generally We will be used to service all of ADVISER‟s clients (including accounts that may not generate commissions used to pay for investment research), but brokerage commissions paid by CLIENT may be used to pay for research that is not used in managing the Account. The Account may pay to a broker-dealer a commission greater than another qualified broker-dealer might charge to effect the same transaction where ADVISER determines in good faith that the commission is reasonable in relation to the value receive any portion of the brokerage and research services receivedcommissions and/or transaction fees charged to you by the Custodian. Transactions for each client account generally will be effected independently, unless ADVISER decides we decide to purchase or sell the same securities for several clients at approximately the same time. ADVISER We may (but is are not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates rates, or to allocate equitably among ADVISER‟s our clients differences in prices price and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among ADVISER‟s our clients in proportion to the purchase and sale orders placed for each client account on any given day. The CLIENT may direct ADVISER to use a particular broker-dealer to execute some or all transactions To the extent that we aggregate client orders for the Account (subject purchase or sale of securities we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall not receive any additional compensation or remuneration as a result of the aggregation. We shall endeavor to ADVISER‟s right to decline and/or terminate the engagement). In such event, CLIENT will negotiate terms and arrangements for the Account with that broker-dealer, and ADVISER will not seek better execution services or prices from other broker-dealers or be able to “batch” CLIENT transactions for execution through other broker-dealers with orders for other accounts managed by ADVISER. As a result, the CLIENT correspondingly acknowledges that such direction may cause the Account to incur higher commission or transaction costs than the Account would otherwise incur had the CLIENT determined to effect process all Account transactions through alternative arrangements in a timely manner, but neither represent nor warrant that may any such transaction shall be available through processed or effected by the ADVISER. In Broker-Dealer on the event that the transactions for the Account are effected through a broker-dealer that refers investment management clients to ADVISER, the potential for conflict of interest may arisesame day as requested.

Execution of Brokerage Transactions. (when applicable). If requested, ADVISER will arrange for the execution of securities brokerage transactions for the Account through broker-dealers that ADVISER reasonably believes will provide “best execution”. In seeking „‘best execution”, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer‟s dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although ADVISER will seek competitive commission rates, it may not necessarily obtain the lowest possible commission rates for Account transactions. Consistent with obtaining best execution, transactions for the Account may be effected through broker-dealers in return for research products and/or services which assist ADVISER in its investment decision making process. Such research generally will be used to service all of ADVISER‟s ADVISER’s clients (including accounts that may not generate commissions used to pay for investment research), but brokerage commissions paid by CLIENT may be used to pay for research that is not used in managing the Account. The Account may pay to a broker-dealer a commission greater than another qualified broker-dealer might charge to effect the same transaction where ADVISER determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. Transactions for each client account generally will be effected independently, unless ADVISER decides to purchase or sell the same securities for several clients at approximately the same time. ADVISER may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among ADVISER‟s ADVISER’s clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among ADVISER‟s ADVISER’s clients in proportion to the purchase and sale orders placed for each client account on any given day. The CLIENT may direct ADVISER to use a particular broker-dealer to execute some or all transactions for the Account (subject to ADVISER‟s ADVISER’s right to decline and/or terminate the engagement). In such event, CLIENT will negotiate terms and arrangements for the Account with that broker-dealer, and ADVISER will not seek better execution services or prices from other broker-dealers or be able to “batch” CLIENT transactions for execution through other broker-dealers with orders for other accounts managed by ADVISER. As a result, the CLIENT correspondingly acknowledges that such direction may cause the Account to incur higher commission or transaction costs than the Account would otherwise incur had the CLIENT determined to effect Account transactions through alternative arrangements that may be available through the ADVISER. In the event that the transactions for the Account are effected through a broker-dealer that refers investment management clients to ADVISER, the potential for conflict of interest may arise.

Execution of Brokerage Transactions. (when applicable). If requestedFor Accounts other than those managed by Independent Managers, ADVISER unless you direct us otherwise, we will arrange for the execution of securities brokerage transactions for the Account Assets through a broker-dealers dealer that ADVISER we reasonably believes believe will provide “best execution”. .” In seeking „best execution”, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a brokerthe Broker-dealer‟s Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although ADVISER we will seek competitive commission rates, it we may not necessarily obtain the lowest possible commission rates for Account transactions. Consistent with obtaining best execution, transactions for the your Account may be effected through directed to registered broker-dealers in return for research products and/or services which that assist ADVISER us in its our investment decision decision-making process. Such research generally will be used to service all of ADVISER‟s clients (including accounts that may not generate commissions used to pay for investment research)our clients, but brokerage commissions paid by CLIENT you may be used to pay for research that is not used in managing the your Account. The Account Thus, you may pay to the Broker-Dealer a broker-dealer a greater commission greater than another qualified broker-dealer might charge to effect the same transaction where ADVISER determines we determine in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. Transactions for each client account generally will be effected independently, unless ADVISER decides we decide to purchase or sell the same securities for several clients at approximately the same time. ADVISER We may (but is are not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates rates, or to allocate equitably among ADVISER‟s our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among ADVISER‟s our clients in proportion to the purchase and sale orders placed for each client account on any given day. The CLIENT To the extent that we aggregate client orders for the purchase or sale of securities, including securities in which our Advisory Affiliates may invest, we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall not receive any additional compensation or remuneration as a result of the aggregation. We shall endeavor to process all Account transactions in a timely manner, but do not represent nor warrant that any such transaction shall be processed or effected by the Broker-Dealer on the same day as requested. You may direct ADVISER us in writing to use a particular broker-dealer (“Directed Broker”) to execute some or all transactions for the your Account (subject referred to ADVISER‟s right to decline and/or terminate the engagementas “directed brokerage”). In such eventthat case, CLIENT you will have the sole responsibility to negotiate terms and arrangements for the Account with that broker-dealer, the Directed Broker and ADVISER we will not seek better execution services or prices from other broker-dealers or be able to “batch” CLIENT transactions for execution through other broker-dealers with orders for other accounts managed by ADVISERwe manage. As a result, the CLIENT correspondingly acknowledges that such direction you may cause the Account to incur pay higher commission commissions or other transaction costs than the Account would otherwise incur had the CLIENT determined to effect Account transactions through alternative arrangements that may be available through the ADVISER. In the event that the costs, greater spreads, or receive less favorable net prices on transactions for the Account are effected through a broker-dealer that refers investment management clients to ADVISER, than would otherwise be the potential for conflict of interest may arisecase.

Execution of Brokerage Transactions. (when applicable). If requested, ADVISER a) Rockingstone will arrange for the execution of securities brokerage transactions for the Account through broker-dealers that ADVISER Rockingstone reasonably believes will provide “best execution”. In seeking „“best execution”, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer‟s dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although ADVISER Rockingstone will seek competitive commission rates, it may not necessarily obtain the lowest possible commission rates for Account transactions. . (b) Consistent with obtaining best execution, transactions for the Account may be effected through broker-dealers in return for research products and/or services which assist ADVISER Rockingstone in its investment decision making process. Such research generally will be used to service all of ADVISER‟s Rockingstone’s clients (including accounts that may not generate commissions used to pay for investment research), but brokerage commissions paid by CLIENT may be used to pay for research that is not used in managing the Account. The Account may pay to a broker-dealer a commission greater than another qualified broker-dealer might charge to effect the same transaction where ADVISER Rockingstone determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. . (c) Transactions for each client account generally will may be effected independently, unless ADVISER Rockingstone decides to purchase or sell the same securities for several clients at approximately the same time. ADVISER Rockingstone may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among ADVISER‟s clients Rockingstone’s clients, differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, generally transactions will be averaged as to price and will be allocated among ADVISER‟s Rockingstone’s clients in proportion to on a pro-rata based upon market value. Rockingstone shall not receive any additional compensation or remuneration as a result of the purchase and sale orders placed for each client account on any given day. The aggregation. (d) CLIENT may direct ADVISER Rockingstone to use a particular broker-dealer to execute some or all transactions for the Account (subject to ADVISER‟s Rockingstone’s right to decline and/or terminate the engagement). In such event, CLIENT will negotiate terms and arrangements for the Account with that broker-dealer, and ADVISER Rockingstone will not seek better execution services or prices from other broker-dealers or be able to “batch” CLIENT transactions for execution through other broker-dealers with orders for other accounts managed by ADVISERRockingstone. As a result, the CLIENT correspondingly acknowledges that such direction may cause the Account to incur pay higher commission commissions or other transaction costs than the Account would otherwise incur had the CLIENT determined to effect Account transactions through alternative arrangements that may be available through the ADVISER. In the event that the or greater spreads, or receive less favorable net prices, on transactions for the Account are effected through a broker-dealer that refers investment management clients to ADVISER, than would otherwise be the potential for conflict of interest may arisecase.

Execution of Brokerage Transactions. (when applicable). If requested, ADVISER Adviser will arrange for the execution of securities brokerage transactions for the Account through brokerBroker-dealers Dealers that ADVISER Adviser reasonably believes will provide “best execution”. In seeking „best execution”, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a brokerBroker-dealer‟s Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although ADVISER Adviser will seek competitive commission rates, it may not necessarily obtain the lowest possible commission rates for Account transactions. Consistent with obtaining best execution, transactions for the Account may be effected through brokerBroker-dealers Dealers in return for research products and/or services which assist ADVISER Adviser in its investment decision making process. Such research generally will be used to service all of ADVISER‟s clients (including accounts that may not generate commissions used to pay for investment research)Adviser’s Clients, but brokerage commissions paid by CLIENT Client may be used to pay for research that is not used in managing the Account. The Account may pay to a brokerBroker-dealer Dealer a commission greater than another qualified brokerBroker-dealer Dealer might charge to effect the same transaction where ADVISER Adviser determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. Transactions for each client Client account generally will be effected independently, unless ADVISER Adviser decides to purchase or sell the same securities for several clients Clients at approximately the same time. ADVISER Adviser may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among ADVISER‟s clients Adviser’s Clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among ADVISER‟s clients Adviser’s Clients in proportion to the purchase and sale orders placed for each client Client account on any given day. To the extent that the Adviser determines to aggregate Client orders for the purchase or sale of securities, including securities in which Adviser’s principal(s) and/or associated person(s) may invest, the Adviser shall generally do so in accordance with the parameters set forth in SEC No-Action Letter, The CLIENT Adviser shall not receive any additional compensation or remuneration as a result of the aggregation. The Client may direct ADVISER Adviser to use a particular brokerBroker-dealer Dealer to execute some or all transactions for the Account (subject to ADVISER‟s Adviser’s right to decline and/or terminate the engagement). In such event, CLIENT the Client will negotiate terms and arrangements for the Account with that brokerBroker-dealerDealer, and ADVISER Adviser will not seek better execution services or prices from other brokerBroker-dealers Dealers or be able to “batch” CLIENT Client transactions for execution through other brokerBroker-dealers Dealers with orders for other accounts managed by ADVISERAdviser. As a result, the CLIENT correspondingly acknowledges that such direction Client may cause pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the Account to incur higher commission or transaction costs than the Account would otherwise incur had be the CLIENT determined to effect Account transactions through alternative arrangements that may be available through the ADVISERcase. In the event that the transactions for the Account are effected through a brokerBroker-dealer Dealer that refers investment management clients Clients to ADVISERthe Adviser, the potential for conflict of interest may arise.

Execution of Brokerage Transactions. (when applicable). If requested, ADVISER Adviser will arrange for the execution of securities brokerage transactions for the Account through brokerBroker-dealers Dealers that ADVISER Adviser reasonably believes will provide “best execution”. In seeking „best execution”, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer‟s Broker- Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although ADVISER Adviser will seek competitive commission rates, it may not necessarily obtain the lowest possible commission rates for Account transactions. Consistent with obtaining best execution, transactions for the Account may be effected through brokerBroker-dealers Dealers in return for research products and/or services which assist ADVISER Adviser in its investment decision making process. Such research generally will be used to service all of ADVISER‟s clients (including accounts that may not generate commissions used to pay for investment research)Adviser’s Clients, but brokerage commissions paid by CLIENT Client may be used to pay for research that is not used in managing the Account. The Account may pay to a brokerBroker-dealer Dealer a commission greater than another qualified brokerBroker-dealer Dealer might charge to effect the same transaction where ADVISER Adviser determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. Transactions for each client Client account generally will be effected independently, unless ADVISER Adviser decides to purchase or sell the same securities for several clients Clients at approximately the same time. ADVISER Adviser may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among ADVISER‟s clients Adviser’s Clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among ADVISER‟s clients Adviser’s Clients in proportion to the purchase and sale orders placed for each client Client account on any given day. To the extent that the Adviser determines to aggregate Client orders for the purchase or sale of securities, including securities in which Adviser’s principal(s) and/or associated person(s) may invest, the Adviser shall generally do so in accordance with the parameters set forth in SEC No-Action Letter, SMC Capital, Inc. The CLIENT Adviser shall not receive any additional compensation or remuneration as a result of the aggregation. The Client may direct ADVISER Adviser to use a particular brokerBroker-dealer Dealer to execute some or all transactions for the Account (subject to ADVISER‟s Adviser’s right to decline and/or terminate the engagement). In such event, CLIENT the Client will negotiate terms and arrangements for the Account with that brokerBroker-dealerDealer, and ADVISER Adviser will not seek better execution services or prices from other brokerBroker-dealers Dealers or be able to “batch” CLIENT Client transactions for execution through other broker-dealers Broker- Dealers with orders for other accounts managed by ADVISERAdviser. As a result, the CLIENT correspondingly acknowledges that such direction Client may cause pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the Account to incur higher commission or transaction costs than the Account would otherwise incur had be the CLIENT determined to effect Account transactions through alternative arrangements that may be available through the ADVISERcase. In the event that the transactions for the Account are effected through a brokerBroker-dealer Dealer that refers investment management clients Clients to ADVISERthe Adviser , the potential for conflict of interest may arise.

Execution of Brokerage Transactions. (when applicable). If requestedUnless directed otherwise, ADVISER we will arrange for the execution of securities brokerage transactions for the Account in your Accounts through a broker-dealers dealer that ADVISER we reasonably believes believe will provide “best execution”.” This may include placing trades with broker-dealers with whom you have entered into arrangements for prime brokerage clearing services. In this event, you will incur both the transaction fee charged by the executing broker-dealer and a “trade-away” fee charged by your Custodian. In seeking „best execution”, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a the broker-dealer‟s dealer’s services including the value of research providedincluding, but not limited to, execution capability, commission ratesrates and/or transaction fees, and responsiveness. Accordingly, although ADVISER we will seek competitive commission ratesrates and/or transaction fees, it we may not necessarily obtain the lowest possible commission rates for Account account transactions. Consistent with obtaining best execution, transactions for the Account in your Accounts may be effected through directed to registered broker-dealers in return for research products and/or services which that assist ADVISER us in its our investment decision decision- making process. Such research generally will be used to service all We may authorize the payment of ADVISER‟s clients (including accounts higher commissions and/or trading costs by your Accounts than those that may not generate commissions used to pay for investment research), but brokerage commissions paid by CLIENT may be used to pay for research that is not used in managing the Account. The Account may pay to a broker-dealer a commission greater than another qualified broker-dealer might charge to effect the same transaction where ADVISER determines otherwise available if we determine in good faith that the amount of such commission cost is reasonable in relation to the value of the research products and/or services provided by the broker-dealer. Such research products and/or services generally will be used to service all of our clients, but brokerage and commissions paid by you may be used to pay for research products and/or services receivedthat are not used for your Account. Transactions for each client account generally will be effected independently, unless ADVISER decides we decide to purchase or sell the same securities for several clients at approximately the same time. ADVISER We may (but is are not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates rates, or to allocate equitably among ADVISER‟s our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among ADVISER‟s our clients in proportion to the purchase and sale orders placed for each client account on any given block that may occur in a given day. The CLIENT To the extent that we aggregate client orders for the purchase or sale of securities, including securities in which our Advisory Affiliates may direct ADVISER invest, we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall not receive any additional compensation or remuneration as a result of the aggregation. We shall endeavor to use process all account transactions in a particular timely manner, but neither represent nor warrant that any such transaction shall be processed or effected by the broker-dealer on the same day as requested. If you choose to execute some or all transactions direct brokerage for the Account (subject your Accounts, you should review our Form ADV, Part 2A for important information relating to ADVISER‟s right to decline and/or terminate the engagement). In such event, CLIENT will negotiate terms and arrangements for the Account with that broker-dealer, and ADVISER will not seek better execution services or prices from other broker-dealers or be able to “batch” CLIENT transactions for execution through other broker-dealers with orders for other accounts managed by ADVISER. As a result, the CLIENT correspondingly acknowledges that such direction may cause the Account to incur higher commission or transaction costs than the Account would otherwise incur had the CLIENT determined to effect Account transactions through alternative arrangements that may be available through the ADVISER. In the event that the transactions for the Account are effected through a broker-dealer that refers investment management clients to ADVISER, the potential for conflict of interest may arisedirected brokerage.

Execution of Brokerage Transactions. (when applicable). If requestedUnless directed otherwise, ADVISER we will arrange for the execution of securities brokerage transactions for the Account Assets through broker-dealers that ADVISER Fidelity who we reasonably believes believe will provide “best execution”. In seeking „best execution”, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a brokerthe Broker-dealer‟s Dealer’s services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although ADVISER we will seek competitive commission rates, it we may not necessarily obtain the lowest possible commission rates for Account transactionstransactions (see Exhibit A below). Consistent with obtaining best execution, transactions for We shall not favor any account over any other and purchase or sale orders executed contemporaneously shall be allocated in a manner we deem equitable among the Account may be effected through broker-dealers in return for research products and/or services which assist ADVISER in its investment decision making process. Such research generally will be used to service all of ADVISER‟s clients (including accounts that may not generate commissions used to pay for investment research), but brokerage commissions paid by CLIENT may be used to pay for research that is not used in managing the Account. The Account may pay to a broker-dealer a commission greater than another qualified broker-dealer might charge to effect the same transaction where ADVISER determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services receivedinvolved. Transactions for each client account generally will sometimes be effected independently, unless ADVISER decides but more often we expect to purchase or sell the same securities for several separate account clients at approximately the same time. ADVISER We may (but is are not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates rates, or to allocate equitably among ADVISER‟s our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among ADVISER‟s our clients in proportion to the purchase and sale orders placed for each client account on any given day. The CLIENT may direct ADVISER to use a particular broker-dealer to execute some or all transactions To the extent that we aggregate client orders for the Account (subject purchase or sale of securities we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall endeavor to ADVISER‟s right to decline and/or terminate the engagement). In such event, CLIENT will negotiate terms and arrangements for the Account with that broker-dealer, and ADVISER will not seek better execution services or prices from other broker-dealers or be able to “batch” CLIENT transactions for execution through other broker-dealers with orders for other accounts managed by ADVISER. As a result, the CLIENT correspondingly acknowledges that such direction may cause the Account to incur higher commission or transaction costs than the Account would otherwise incur had the CLIENT determined to effect process all Account transactions through alternative arrangements in a timely manner, but do not represent nor warrant that may any such transaction shall be available through processed or effected by Fidelity on the ADVISERsame day as requested. In the event that the transactions for the Account are effected through a broker-dealer that refers investment management clients to ADVISER, the potential for conflict of interest may arise._______________________________________________

Execution of Brokerage Transactions. As previously mentioned, we are your Financial Strategists and, as such, are responsible for managing the relationship between you and the Custodian of the assets (when applicable)Altruist) and managing your investment portfolio. If requestedAs such and unless directed otherwise, ADVISER we will arrange for the execution of securities brokerage transactions for the Account Assets through broker-dealers a broker- dealer that ADVISER we reasonably believes believe will provide “best execution”. .” In seeking „best execution”, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of a brokerthe Broker-dealer‟s Dealer's services including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although ADVISER we will seek competitive commission rates, it we may not necessarily obtain the lowest possible commission rates for Account transactions. Neither we, nor any of our Associated Persons, will receive any portion of the brokerage commissions and/or transaction fees charged to you by the Broker-Dealer. Consistent with obtaining best execution, transactions for the your Account may be effected through directed to registered broker-dealers in return for research products and/or services which that assist ADVISER us in its our investment decision decision-making process. Such research generally will be used to service all of ADVISER‟s clients (including accounts that may not generate commissions used to pay for investment research)our clients, but brokerage commissions paid by CLIENT you may be used to pay for research that is not used in managing the your Account. The Account Thus, you may pay to the Broker-Dealer a broker-dealer a greater commission greater than another qualified broker-dealer might charge to effect the same transaction where ADVISER determines we determine in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. Transactions for each client account generally will be effected independently, effectuated independently unless ADVISER decides we decide to purchase or sell the same securities for several clients at approximately the same time. ADVISER We may (but is are not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates rates, or to allocate equitably among ADVISER‟s our clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among ADVISER‟s our clients in proportion to the purchase and sale orders placed for each client account on any given day. The CLIENT may direct ADVISER to use a particular broker-dealer to execute some or all transactions To the extent that we aggregate client orders for the Account purchase or sale of securities, including securities in which persons associated with us (subject as defined in the Advisers Act, hereafter “Associated Person(s)”) may invest, we shall do so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the Securities and Exchange Commission. We shall not receive any additional compensation or remuneration as a result of the aggregation. We shall endeavor to ADVISER‟s right to decline and/or terminate the engagement). In such event, CLIENT will negotiate terms and arrangements for the Account with that broker-dealer, and ADVISER will not seek better execution services or prices from other broker-dealers or be able to “batch” CLIENT transactions for execution through other broker-dealers with orders for other accounts managed by ADVISER. As a result, the CLIENT correspondingly acknowledges that such direction may cause the Account to incur higher commission or transaction costs than the Account would otherwise incur had the CLIENT determined to effect process all Account transactions through alternative arrangements in a timely manner, but do not represent or warrant that may any such transaction shall be available through processed or effected by the ADVISER. In Broker-Dealer on the event that the transactions for the Account are effected through a broker-dealer that refers investment management clients to ADVISER, the potential for conflict of interest may arisesame day as requested.