RHBAM (“Company”) may undertake cross trade transactions between fund(s) or portfolio(s) [for clients who have entered into an Investment Management Agreement with the Company].

Cross trade transactions between two or more funds/portfolios managed by the Company, may be undertaken provided that:

i. The decisions are deemed to be in the best interest of both fund(s) and/or portfolio(s);

ii. Reason for such transactions is documented prior to execution of the trades;

iii. Transactions are executed through a dealer or a financial institution on an arm’s length and fair value basis;

iv. Cross trades transactions are disclosed in the funds’ report and/or to clients (for the portfolios), as the case maybe.

Cross trades between employee of Company and the funds/clients’ portfolio(s), and cross trades between proprietary account and the funds’ account(s)/clients’ accounts are strictly prohibited.