Common use of Investment Adviser Review Clause in Contracts

Investment Adviser Review. The review of the policies and procedures of each Fund’s investment adviser shall cover, among other things, to the extent applicable to such Fund, policies and procedures governing and/or applicable to: (i) Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios with clients' investment objectives, disclosures by the Fund, and applicable regulatory restrictions; (ii) Trading practices, including procedures by which the Fund satisfies its best execution obligation, uses client brokerage to obtain research and other services (“soft dollar arrangements”), and allocates aggregated trades among clients; (iii) Portfolio trading of the Fund and personal trading activities of supervised persons; (iv) The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements; (v) Safeguarding of client assets from conversion or inappropriate use by advisory personnel; (vi) The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction; (vii) Marketing of advisory services, including the use of solicitors; (viii) Processes to value client holdings and assess fees based on those valuations; (ix) Safeguards for the privacy protection of client records and information; and (x) Business continuity plans. It is understood that the chief compliance officer of each Fund’s investment adviser is primarily responsible for compliance by such organization with Rule 206(4)-7 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and for overseeing, with respect to the portfolios they advise, each of the foregoing items. Nothing contained herein shall be construed to require NLCS to perform any service that could cause NLCS to be deemed an investment adviser for purposes of the Investment Company Act or the Advisers Act or that could cause a Fund to act in contravention of the Fund’s prospectus or any provision of the Investment Company Act.

Investment Adviser Review. The review of the policies and procedures of each Fund’s investment adviser shall cover, among other things, to the extent applicable to such Fund, policies and procedures governing and/or applicable to: (i) Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios with clients' ’ investment objectives, disclosures by the Fund, and applicable regulatory restrictions; (ii) Trading practices, including procedures by which the Fund satisfies its best execution obligation, uses client brokerage to obtain research and other services (“soft dollar arrangements”), and allocates aggregated trades among clients; (iii) Portfolio trading of the Fund and personal trading activities of supervised persons; (iv) The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements; (v) Safeguarding of client assets from conversion or inappropriate use by advisory personnel; (vi) The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction; (vii) Marketing of advisory services, including the use of solicitors; (viii) Processes to value client holdings and assess fees based on those valuations; (ix) Safeguards for the privacy protection of client records and information; and (x) Business continuity plans. It is understood that the chief compliance officer of each Fund’s investment adviser is primarily responsible for compliance by such organization with Rule 206(4)-7 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and for overseeing, with respect to the portfolios they advise, each of the foregoing items. Nothing contained herein shall be construed to require NLCS to perform any service that could cause NLCS to be deemed an investment adviser for purposes of the Investment Company Act or the Advisers Act or that could cause a Fund to act in contravention of the Fund’s prospectus or any provision of the Investment Company Act.

Investment Adviser Review. The review of the policies and procedures of each Fund’s investment adviser shall cover, among other things, to the extent applicable to such Fund, policies and procedures governing and/or applicable to: (i) Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios with clients' investment objectives, disclosures by the Fund, and applicable regulatory restrictions; (ii) Trading practices, including procedures by which the Fund satisfies its best execution obligation, uses client brokerage to obtain research and other services (“soft dollar arrangements”), and allocates aggregated trades among clients; (iii) Portfolio Proprietary trading of the Fund and personal trading activities of supervised persons; (iv) The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements; (v) Safeguarding of client assets from conversion or inappropriate use by advisory personnel; (vi) The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction; (vii) Marketing of advisory services, including the use of solicitors; (viii) Processes to value client holdings and assess fees based on those valuations; (ix) Safeguards for the privacy protection of client records and information; and (x) Business continuity plans. It is understood that the chief compliance officer of each Fund’s investment adviser is primarily responsible for compliance by such organization with Rule 206(4)-7 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and for overseeing, with respect to the portfolios they advise, each of the foregoing items. Nothing contained herein shall be construed to require NLCS to perform any service that could cause NLCS to be deemed an investment adviser for purposes of the Investment Company Act or the Advisers Act or that could cause a Fund to act in contravention of the Fund’s prospectus or any provision of the Investment Company Act.

Investment Adviser Review. The review of the policies and procedures of each the Fund’s investment adviser shall cover, among other things, to the extent applicable to such the Fund, policies and procedures governing and/or applicable to: (i) Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios the portfolio with clients' ’ investment objectives, disclosures by the Fund, and applicable regulatory restrictions; (ii) Trading practices, including procedures by which the Fund satisfies its best execution obligation, uses client brokerage to obtain research and other services (“soft dollar arrangements”), and allocates aggregated trades among clients; (iii) Portfolio trading of the Fund and personal trading activities of supervised persons; (iv) The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements; (v) Safeguarding of client assets from conversion or inappropriate use by advisory personnel; (vi) The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction; (vii) Marketing of advisory services, including the use of solicitors; (viii) Processes to value client holdings and assess fees based on those valuations; (ix) Safeguards for the privacy protection of client records and information; and (x) Business continuity plans. It is understood that the chief compliance officer of each the Fund’s investment adviser is primarily responsible for compliance by such organization with Rule 206(4)-7 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and for overseeing, with respect to the portfolios they advise, each of the foregoing items. Nothing contained herein shall be construed to require NLCS to perform any service that could cause NLCS to be deemed an investment adviser for purposes of the Investment Company Act or the Advisers Act or that could cause a the Fund to act in contravention of the Fund’s prospectus or any provision of the Investment Company Act.

Investment Adviser Review. The review of the policies and procedures of each the Fund’s investment adviser shall cover, among other things, to the extent applicable to such the Fund, policies and procedures governing and/or applicable to: (i) Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios the portfolio with clients' investment objectives, disclosures by the Fund, and applicable regulatory restrictions; (ii) Trading practices, including procedures by which the Fund satisfies its best execution obligation, uses client brokerage to obtain research and other services (“soft dollar arrangements”), and allocates aggregated trades among clients; (iii) Portfolio Proprietary trading of the Fund and personal trading activities of supervised persons; (iv) The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements; (v) Safeguarding of client assets from conversion or inappropriate use by advisory personnel; (vi) The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction; (vii) Marketing of advisory services, including the use of solicitors; (viii) Processes to value client holdings and assess fees based on those valuations; (ix) Safeguards for the privacy protection of client records and information; and (x) Business continuity plans. It is understood that the chief compliance officer of each the Fund’s investment adviser is primarily responsible for compliance by such organization with Rule 206(4)-7 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and for overseeing, with respect to the portfolios they advise, each of the foregoing items. Nothing contained herein shall be construed to require NLCS to perform any service that could cause NLCS to be deemed an investment adviser for purposes of the Investment Company Act or the Advisers Act or that could cause a the Fund to act in contravention of the Fund’s prospectus or any provision of the Investment Company Act.

Investment Adviser Review. The review of the policies and procedures of each Fund’s investment adviser shall cover, among other things, to the extent applicable to such Fund, policies and procedures governing and/or applicable to: (i) Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios with clients' ’ investment objectives, disclosures by the Fund, and applicable regulatory restrictions; (ii) Trading practices, including procedures by which the Fund satisfies its best execution obligation, uses client brokerage to obtain research and other services (“soft dollar arrangements”), and allocates aggregated trades among clients; (iii) Portfolio Proprietary trading of the Fund and personal trading activities of supervised persons; (iv) The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements; (v) Safeguarding of client assets from conversion or inappropriate use by advisory personnel; (vi) The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction; (vii) Marketing of advisory services, including the use of solicitors; (viii) Processes to value client holdings and assess fees based on those valuations; (ix) Safeguards for the privacy protection of client records and information; and (x) Business continuity plans. It is understood that the chief compliance officer of each Fund’s investment adviser is primarily responsible for compliance by such organization with Rule 206(4)-7 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and for overseeing, with respect to the portfolios they advise, each of the foregoing items. Nothing contained herein shall be construed to require NLCS to perform any service that could cause NLCS to be deemed an investment adviser for purposes of the Investment Company Act or the Advisers Act or that could cause a Fund to act in contravention of the Fund’s prospectus or any provision of the Investment Company Act.

Investment Adviser Review. The review of the policies and procedures of each Fund’s investment adviser shall cover, among other things, to the extent applicable to such Fund, policies and procedures governing and/or applicable to: (i) Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios with clients' ’ investment objectives, disclosures by the Fund, and applicable regulatory restrictions; (ii) Trading practices, including procedures by which the Fund satisfies its best execution obligation, uses client brokerage to obtain research and other services (“soft dollar arrangements”), and allocates aggregated trades among clients; (iii) Portfolio trading of the Fund and personal trading activities of supervised persons; (iv) The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements; (v) Safeguarding of client assets from conversion or inappropriate use by advisory personnel; (vi) The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction; (vii) Marketing of advisory services, including the use of solicitors; (viii) Processes to value client holdings and assess fees based on those valuations; (ixviii) Safeguards for the privacy protection of client records and information; and (xix) Business continuity plans. It is understood that the chief compliance officer of each Fund’s investment adviser is primarily responsible for compliance by such organization with Rule 206(4)-7 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and for overseeing, with respect to the portfolios they advise, each of the foregoing items. Nothing contained herein shall be construed to require NLCS to perform any service that could cause NLCS to be deemed an investment adviser for purposes of the Investment Company Act or the Advisers Act or that could cause a Fund to act in contravention of the Fund’s prospectus or any provision of the Investment Company Act.

Investment Adviser Review. The review of the policies and procedures of each the Fund’s investment adviser shall cover, among other things, to the extent applicable to such the Fund, policies and procedures governing and/or applicable to: (i) Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios the portfolio with clients' ’ investment objectives, disclosures by the Fund, and applicable regulatory restrictions; (ii) Trading practices, including procedures by which the Fund satisfies its best execution obligation, uses client brokerage to obtain research and other services (“soft dollar arrangements”), and allocates aggregated trades among clients; (iii) Portfolio Proprietary trading of the Fund and personal trading activities of supervised persons; (iv) The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements; (v) Safeguarding of client assets from conversion or inappropriate use by advisory personnel; (vi) The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction; (vii) Marketing of advisory services, including the use of solicitors; (viii) Processes to value client holdings and assess fees based on those valuations; (ix) Safeguards for the privacy protection of client records and information; and (x) Business continuity plans. It is understood that the chief compliance officer of each the Fund’s investment adviser is primarily responsible for compliance by such organization with Rule 206(4)-7 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and for overseeing, with respect to the portfolios they advise, each of the foregoing items. Nothing contained herein shall be construed to require NLCS to perform any service that could cause NLCS to be deemed an investment adviser for purposes of the Investment Company Act or the Advisers Act or that could cause a the Fund to act in contravention of the Fund’s prospectus or any provision of the Investment Company Act.

Investment Adviser Review. The review of the policies and procedures of each the Fund’s investment adviser shall cover, among other things, to the extent applicable to such the Fund, policies and procedures governing and/or applicable to: (i) Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios the portfolio with clients' investment objectives, disclosures by the Fund, and applicable regulatory restrictions; (ii) Trading practices, including procedures by which the Fund satisfies its best execution obligation, uses client brokerage to obtain research and other services (“soft dollar arrangements”), and allocates aggregated trades among clients; (iii) Portfolio trading of the Fund and personal trading activities of supervised persons; (iv) The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements; (v) Safeguarding of client assets from conversion or inappropriate use by advisory personnel; (vi) The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction; (vii) Marketing of advisory services, including the use of solicitors; (viii) Processes to value client holdings and assess fees based on those valuations; (ix) Safeguards for the privacy protection of client records and information; and (x) Business continuity plans. It is understood that the chief compliance officer of each the Fund’s investment adviser is primarily responsible for compliance by such organization with Rule 206(4)-7 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and for overseeing, with respect to the portfolios they advise, each of the foregoing items. Nothing contained herein shall be construed to require NLCS to perform any service that could cause NLCS to be deemed an investment adviser for purposes of the Investment Company Act or the Advisers Act or that could cause a the Fund to act in contravention of the Fund’s prospectus or any provision of the Investment Company Act.

Investment Adviser Review. The review of the policies and procedures of each the Fund’s investment adviser shall cover, among other things, to the extent applicable to such the Fund, policies and procedures governing and/or applicable to: (i) Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios the portfolio with clients' investment objectives, disclosures by the Fund, and applicable regulatory restrictions; (ii) Trading practices, including procedures by which the Fund satisfies its best execution obligation, uses client brokerage to obtain research and other services (“soft dollar arrangements”), and allocates aggregated trades among clients; (iii) Portfolio trading of the Fund and personal trading activities of supervised persons; (iv) The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements; (v) Safeguarding of client assets from conversion or inappropriate use by advisory personnel; (vi) The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction; (vii) Marketing of advisory services, including the use of solicitors; (viii) Processes to value client holdings and assess fees based on those valuations; ; (ix) Safeguards ix)Safeguards for the privacy protection of client records and information; and (x) Business continuity plans. It is understood that the chief compliance officer of each the Fund’s investment adviser is primarily responsible for compliance by such organization with Rule 206(4)-7 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and for overseeing, with respect to the portfolios they advise, each of the foregoing items. Nothing contained herein shall be construed to require NLCS to perform any service that could cause NLCS to be deemed an investment adviser for purposes of the Investment Company Act or the Advisers Act or that could cause a the Fund to act in contravention of the Fund’s prospectus or any provision of the Investment Company Act.

Investment Adviser Review. The review of the policies and procedures of each Fund’s 's investment adviser shall cover, among other things, to the extent applicable to such Fund, policies and procedures governing and/or applicable to: (i) Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios with clients' investment objectives, disclosures by the Fund, and applicable regulatory restrictions; (ii) Trading practices, including procedures by which the Fund satisfies its best execution obligation, uses client brokerage to obtain research and other services (“"soft dollar arrangements”"), and allocates aggregated trades among clients; (iii) Portfolio Proprietary trading of the Fund and personal trading activities of supervised persons; (iv) The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements; (v) Safeguarding of client assets from conversion or inappropriate use by advisory personnel; (vi) The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction; (vii) Marketing of advisory services, including the use of solicitors; (viii) Processes to value client holdings and assess fees based on those valuations; (ix) Safeguards for the privacy protection of client records and information; and (x) Business continuity plans. It is understood that the chief compliance officer of each Fund’s 's investment adviser is primarily responsible for compliance by such organization with Rule 206(4)-7 under the Investment Advisers Act of 1940, as amended (the “"Advisers Act”"), and for overseeing, with respect to the portfolios they advise, each of the foregoing items. Nothing contained herein shall be construed to require NLCS to perform any service that could cause NLCS to be deemed an investment adviser for purposes of the Investment Company Act or the Advisers Act or that could cause a Fund to act in contravention of the Fund’s 's prospectus or any provision of the Investment Company Act.