Best Execution Policy

1.           Introduction

Pure North Markets (hereafter “the Company”) is an Investment Dealer (Full ServiceDealer, Excluding Underwriting) which operates as Investment Dealer. The Company is incorporatedin the Republic of Mauritius and is authorized and regulated by the Financial Services Commission (hereafter “FSC”) with License Number GB21026474.Company’s registered address is at C/o Alexander Management Services Limited3 Emerald Park,Trianon, Quatres Bornes,72257 Republic of Mauritius

2.           Purpose

The Company is required to establish, implement and maintain a policy on conflicts of interest and provide information regarding the adequate man-aging of any conflicts of interestbetween itself, including its managers and employees, tied agents or other relevantpersons, as well as any per-son directly or indirectly linked to them by control, and their clients or

be-tween oneclient andanother that arise inthe course of providing any in-vestment and ancillary services.

The conflicts ofinterest policy is applicable to allclients, including retail clients, professional clients and eligible counterparties.

3.           Identification ofPotential Conflicts of Interest

For the purposesof identifying the types of conflict of interest that arise in the course ofproviding investment and ancillary servicesor a combination thereof and whose existence may damage the interestsof a client, the Companytakes into account,by way of minimum criteria,whether the Company or a relevant person, or a person directly or indirectly linked by control to the Company,is in any of the following situations, whether as a result of providinginvestment or ancillaryservices or investment activities or otherwise:

a)                          the Company or arelevant person, or a person directly or indirectly linked by control to the Companyis likely to make a financial gain, or avoid a financialloss, at the expenseof the client;

b)                         the Company or arelevant person, or a person directly or indirectly linked by control to the Companyhas an interest in the outcome of a serviceprovided to the client or of a transaction carriedout on behalf of the client, whichis distinct from theclient's interest in that outcome;

c)                          the Company or arelevant person, or a person directly or indirectly linked by control to the Companyhas a financial or otherincentive to favourthe interest of another client or group of clientsover the interests of the client;

d)                         the Company or arelevant person, or a person directly or indirectly linked to the Company carries on the same businessas the client;

e)                          the Company or arelevant person, or a person directly or indirectly linked by control to the Company receives or will receive from a person other than the clientan inducement in relation to a service provided to the client, in theform of monetary or non-monetary benefits or services.

Relevant person in relation to theCompany means any ofthe following persons:

a)                          a director, partner orequivalent, manager or tied agent ofthe firm;

b)                         a director, partner orequivalent, ormanager ofany tied agent ofthe firm;

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c)                          an employeeof the firm or of a tied agent of the firm, as well as any other natural person whose services are placed at the disposal and under the control of the firm or a tied agent of the firm and who isinvolved in the provision by the firm of investment services and activities;

d)                         a natural person whois directly involved in the provision of services to the investment firm or toits tied agent under an outsourcing arrangement for the purpose of the provisionby the firm of investment services and activities

If aconflict ofinterest arises, the affected parties canbe theCompany, itsemployees orits clients. More specifically, a conflict of interest may arise betweenthe following parties:

(a)                      Betweenthe client and the Company.

(b)                      Between twoclients ofthe Company.

(c)                       Between theCompany anda relevant person ofthe Company.

(d)                      Between aclient ofthe Company and arelevant person of theCompany.

(e)                      Between Company’s Departments.

4.           Reporting Conflicts of Interest

In the case of identification of a possibleconflict of interest, a staff membermust refer it initially to his immediate supervisor to assistin the assessment of a material risk of damage and inform Compliance Department together with full details to allow regulatory scrutiny, of:

(i)                         Corrective andpreventive actions;

(ii)                       How these actions were considered appropriate;

(iii)                    Any conditions imposed; and

(iv)                     Whether there are still ongoing conflicts,how these are being managedand advised to the client.

5.           Procedures and Measures forthe Management of Conflicts of

Interest

The Company maintainsa compliance department that is independent within the Company, and it is withinthe duties of the Compliance Department to monitorthe Company’s Conflicts Policy and practices for any possibleviolation, as well as for managing any possible conflicts of interest. The Companyhas established suitableand adequate internalprocedures for minimizing any potential conflictsof interest which include the following:

(A)          Independence

The following measureshave been adoptedby the Company for ensuringthe requisite degree ofindependence appropriate to the size and activities of the Company:

(i)                         Measures to preventor control the exchange of information between relevant persons engaged inactivities involving a risk of a conflict of interest (i.e., by establishing aChinese wall):

-                                The Companyhas constructed adequateChinese Walls, in accordance with thelegal requirements betweenits departments and has established clear lines of responsibility, in order to avoid the flow of information held by a person in thecourse of carrying out a part of its businessto be withheld from or used by persons who are in the process ofcarrying out another part of its business.

-                                In particular, physical barriers have been established in order the flow of information is restricted between employees, access has been limited in relationto information and documentation and communication has been restricted between certain employees duringthe course of carrying out their partsof business.

(ii)                       Separate supervisionof relevant persons whose principal functions involve carrying out activitieson behalf of, or providing services to, clients whose interestsmay conflict, or who otherwiserepresent different interests that may conflict,including those of the Company.

(iii)                    Segregation ofduties and supervision for persons engaged in different business activitiesincluding procedures for ensuring appropriate communication betweenbusiness units.

(iv)                     Removal of any directlink between the remuneration of relevant persons principally engagedwith one activityand the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity,where a conflictof interest may arise in relation to those activities.

(v)                        Dealing room employees donot relate their remuneration with clients’ performance.

(vi)                     Proper controls to ensure that noimproper inducements are given or received, and proper inducements are disclosed appropriately.

(vii)                  Measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary servicesor activities. Additionally, the person who decides or influences an individual’sbonus may exert undue influence over that individual’s integrity of judgment.

(viii)                Measures to prevent or control the simultaneous or sequential involvement of a relevant personin separate investment or ancillary servicesor activities such asreception and transmission of clients’ orders and tasks such as portfoliodecision-making and calculating performance.

(ix)                     Segregation ofduties that may give rise toconflicts ofinterest ifcarried onby the same individual.

(B)          Disclosure of conflict of interest

When the measurestaken by the Company to manage conflictsof interest are not sufficient to ensure, with reasonable confidence that risksof damage to clients’ interestwill be prevented, the Company proceedswith the disclosure of conflicts of interest to the client.

Prior to carry out atransaction orprovide aninvestment oran ancillary service toa client, the Company must discloseany actual or potential conflictof interest to the client.The disclosure will be made in sufficient time and in a durablemean and shall include sufficient detail, taking into account the nature of the client, source of conflicts of interest, the risks to the client to enable him to take an informed decisionwith respect to the investment or ancillary service in the contextof which the conflict of interest arises.Where the Company will consider that a disclosure is not sufficientto manage a conflict, we may choose not to proceed with the transaction or matter givingrise to the conflict. Clientswill be given theopportunity to decide on whether to continue their relationship with us with no unreasonableobstacles.

(C)          Record keeping

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The Company keeps and regularlyupdates a record of the kinds of investment and ancillaryservice or investment activity carried out by or on behalf of the Company in which a conflict of interest entailing a material risk of damageto the interests of one or more clients has arisen,or, in the case of an ongoingservice or activity, may arise.

(D)         Responsibilities

The Company’s Chief Executive Officer and theCompliance Officer are responsible for clearly allocating responsibility and delegating authorityto accountable individuals to ensure that those involved are aware of their involvement.

The Company’s employees are required to identify new conflicts of interest arising outof the activities/services that they performand engage in the processto notify line managementupon identifying any potential conflict.

The responsible person for the day to day management of the implementation of this Policy isthe Compliance Officer.

6.           Amendment/Review

The Company reserves the right to amend the current Policy atits discretion and atany time it considers suitable and appropriate and that shall be at least annually.

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