Policy On Cross Trades

The Manager may undertake cross trades between Funds it is currently managing through approved licensed financial institutions subject to and in accordance with the provisions of relevant laws, regulations and guidelines. The Manager’s policy on cross trades shall apply as follows:

(i)    A cross trade arises when a security is sold from one portfolio to another on the same day. Cross trades are effected through approved licensed financial institutions, with supporting justification for the cross trades indicating purpose of disposal from the selling portfolio and purchase for the investing portfolio.

(ii)    All cross trades for equity and fixed income securities must be approved by the Managing Director and all transactions for equity securities will be reported to the Investment Committee.

(iii)   There should be proper documents made available for audit in respect of the above transactions.