Common use of Principle of Fair Allocation of Investment Opportunities Clause in Contracts

Principle of Fair Allocation of Investment Opportunities. In order to ensure fairness in the allocation of investment opportunities among the funds managed and sub-advised by the Manager, the Manager will allocate investment opportunities in compliance with securities regulations and with consideration to the prime determinants of market exposure, cash availability and industry sector exposure and with regard to the suitability of such investments to each fund. In determining the suitability of each investment opportunity to a fund, consideration will be given to a number of factors, the most important being the fund’s investment objectives and strategies, existing portfolio composition and cash levels. Where an investment opportunity is suitable for two or more funds the Manager will allocate the opportunity equitably in order to ensure that funds have equal access to the same quality and quantity of investment opportunities, and in determining such allocations will consider a variety of factors and principles, including, but not limited to, the following: • Legal and regulatory restrictions. • The need within a particular fund for liquidity. • Other investment opportunities that may be available to a fund. • The duration of investments in a fund portfolio. • Each fund’s own investment restrictions. • Where allocation of an investment opportunity would be insufficient to make up a meaningful portion of an individual fund’s portfolio. • Transactions are allocated promptly The allocation for each participation must be documented by the compliance department. Taking into consideration the prime determinants described below and/or specific fund objectives and restrictions, certain investments will not be allocated across all funds. If any deviation from the investment trade allocation policy is noted, the credit committee is notified in writing. Any corrective action to be taken or follow-up explanations will be noted in writing. Prime Determinants: (i) Portfolio duration; (ii) Investment suitability; (iii) Investment exposure; and (iv) Cash availability.

Principle of Fair Allocation of Investment Opportunities. In order to ensure fairness in the allocation of investment opportunities among the funds managed and sub-advised by the Manager, the Manager will allocate investment opportunities in compliance with securities regulations and with consideration to the prime determinants of market exposure, cash availability and industry sector exposure and with regard to the suitability of such investments to each fund. In determining the suitability of each investment opportunity to a fund, consideration will be given to a number of factors, the most important being the fund’s investment objectives and strategies, existing portfolio composition and cash levels. Where an investment opportunity is suitable for two or more funds the Manager will allocate the opportunity equitably in order to ensure that funds have equal access to the same quality and quantity of investment opportunities, and in determining such allocations will consider a variety of factors and principles, including, but not limited to, the following: •  Legal and regulatory restrictions. •  The need within a particular fund for liquidity. •  Other investment opportunities that may be available to a fund. •  The duration of investments in a fund portfolio. •  Each fund’s own investment restrictions. •  Where allocation of an investment opportunity would be insufficient to make up a meaningful portion of an individual fund’s portfolio. •  Transactions are allocated promptly The allocation for each participation must be documented by the compliance department. Taking into consideration the prime determinants described below and/or specific fund objectives and restrictions, certain investments will not be allocated across all funds. If any deviation from the investment trade allocation policy is noted, the credit committee is notified in writing. Any corrective action to be taken or follow-up explanations will be noted in writing. Prime Determinants: (i) Portfolio duration; (ii) Investment suitability; (iii) Investment exposure; and (iv) Cash availability.