STATEMENT OF POLICY ON THE MANAGEMENT OF CONFLICTS OF INTEREST IN RELATION TO INVESTMENT RESEARCH

Scope

This Statement of Policy relates to the Investment Research publications produced by a KUSH JITESH GHODASARA (“KUSH JITESH GHODASARA”) and it outlines the arrangements that seek to ensure that these publications are produced independently and impartially, and that they are not influenced by any potential conflicts of interest arising from our other activities.

Investment Research may include recommendations but they are not intended as an offer or solicitation to engage in specific transactions in securities, financial instruments or strategies. Additionally, Investment Research will not take into account the particular investment objectives, financial conditions, or needs of individual clients and it should not be considered as investment advice.

Purpose of this Statement of Policy

This Statement of Policy is designed to provide an overview of the arrangements employed by KUSH JITESH GHODASARA, which seek to ensure that its Investment Research publications are produced independently and impartially, and in particular that they are not affected by any actual or potential conflicts of interest that may arise from other activities of KUSH JITESH GHODASARA.

This Statement of Policy is particularly directed at the recipients of KUSH JITESH GHODASARA Investment Research, in order that they can properly understand the context in which the Investment Research has been prepared and distributed, and in particular how KUSH JITESH GHODASARA has sought to take all reasonable steps to prevent conflicts of interest from giving rise to a material risk of damage to the interests of its clients.

This Statement of Policy is Intended:

The production and distribution of Investment Research publications by KUSH JITESH GHODASARA, and the activities of KUSH JITESH GHODASARA Investment Research analysts, are governed by the Code of Conduct Applicable to Research Activities within KUSH JITESH GHODASARA, which states that:

"KUSH JITESH GHODASARA seeks to adhere to the highest professional ethical standards in order to best serve the interests of its clients. This Code of Conduct sets forth the principles on which the KUSH JITESH GHODASARA will prepare and issue Research and defines the professional duties of the analysts. All Research is produced in accordance with this code and each Research Function must implement procedures to comply with the relevant aspects of this code."

Outlines of the key arrangements relied on to ensure independence and impartiality in the production and distribution of Investment Research publications are set out in the following sections of the Statement of Policy.

This Statement of Policy is Intended:

• To support the commercial imperative to adhere to high professional and ethical standards in serving the best interests of KUSH JITESH GHODASARA clients;
• To outline of the key arrangements relied on to ensure independence and impartiality in the production and distribution of Investment Research publications as set out in the succeeding sections of the Statement of Policy;

The Research Function:

Governance, supervision and remuneration

KUSH JITESH GHODASARA Investment Research analysts are qualified and registered with appropriate regulatory authorities as necessary. KUSH JITESH GHODASARA Investment Research analysts are not involved in the solicitation or provision of investment banking services. Research analysts are not permitted to attend client pitches and are not allowed to be active participants at offering related investor road-shows. KUSH JITESH GHODASARA Investment Research analysts may not trade for their personal accounts or accounts over which they have an influence in securities issued by or in relation to companies in the sector(s) which they cover, or in derivatives relating to such securities or companies. Any personal account dealing by KUSH JITESH GHODASARA Investment Research analysts is governed by policies and procedures on personal account dealing, which require the registration of dealing accounts and the pre-approval of trades.

KUSH JITESH GHODASARA Investment Research analysts are also required to observe policies and procedures concerning the giving or receiving of gifts or entertainment. These policies and procedures limit the value of gifts or entertainment that may be given or received. Where the value of a gift or entertainment offered or received exceeds certain pre-determined thresholds or does not conform to the policy, it must not be offered or accepted unless it is pre-approved by management and Compliance.

The purpose of this policy is to allay any concern that a conflict of interest might be created. All Investment Research publications must carry the analyst’s certification that:

• The views expressed in the Investment Research publication accurately reflect their personal views about the issuers or securities covered; and
• No part of their compensation was, is, or will be related, directly or indirectly, to the specific recommendations or views expressed in the Investment Research publication.

Editorial and approval processes

The Research function has defined editorial and approval processes that are designed to ensure that Investment Research publications:

• Are fair, clear, not misleading and prepared in good faith, and the basis on which any opinion or analysis is expressed is supported by appropriate due diligence and relevant data;
• Identify the reliable sources used for the Investment Research;
• Identify the valuation methods and assumptions employed;
• Identify the Investment Research analyst that is the author of the Investment Research publication;
• Provide the date of the first distribution of the Investment Research publication;
• Contain only information which is available from public sources;
• Avoid sensationalism or provocative language;
• Adequately disclose where information is reproduced from third party sources; and
• Contain appropriate Disclosures and Disclaimers.

Disclosures

KUSH JITESH GHODASARA seeks to take all reasonable steps to prevent conflicts of interest from giving rise to a material risk of damage to the interests of its clients. KUSH JITESH GHODASARA discloses in its Investment Research publications those factors that might give rise to a perception that an Investment Research analyst’s independence could be compromised.

In the event that it is decided to terminate coverage of a company/issue, the final Investment Research publication on the company/issue will make this clear, and explain the reasons for the termination of coverage. To manage your publication alerts, please visit the “My Alerts” section of “My GlobalMarkets”. From time to time, KUSH JITESH GHODASARA may be required to restrict research its publication or distribution of Investment Research due to certain restrictions as determined, on case-by-case basis, by the Compliance or Legal Departments of KUSH JITESH GHODASARA or based upon advice of Counsel.

Audience

KUSH JITESH GHODASARA Investment Research publications are intended for viewers, readers, institutional clients, qualified institutional buyers, professional investors or professional clients as defined within local laws of the countries in which KUSH JITESH GHODASARA Investment Research publications are distributed.

Other Organizational and Administrative Arrangements Designed to Identify and Manage Conflicts of Interest

KUSH JITESH GHODASARA seeks to ensure that Investment Research analysts are not exposed to non-public information, which cannot be included (or relied on) in their Investment Research publications.

Information barriers around Investment Research function related to public-side businesses of KUSH JITESH GHODASARA In addition to the barriers described above, the Investment Research function is separated so as to manage the restricted interaction with other public-side businesses within KUSH JITESH GHODASARA appropriately, and to preserve the confidential nature of non-published research materials and/or information.

Whistleblower Program

KUSH JITESH GHODASARA has committed to handling any reported breaches of its Code of Conduct in a confidential manner according to its whistleblower framework. Employees are encouraged to use a hotline in their region, where available, to report issues and consult with Compliance personnel.

Understanding this Statement of Policy

As described above, this Statement of Policy is designed to provide an overview of the policies and procedures of KUSH JITESH GHODASARA that are intended to ensure its Investment Research publications are produced independently and impartially, and in particular that these publications are not affected by any actual or potential conflicts of interest that may arise from our other activities. Publication and provision of this Statement of Policy is for information purposes only and does not create any third-party rights or duties that would not otherwise exist, nor does it form part of any contractual arrangement between KUSH JITESH GHODASARA and any existing or potential client.