CFM BH Focused Growth Index SRI Operating Memorandum

Custodian & Broker The Strategy Manager has appointed Capital International Limited (“CIL”) of Mill Court, Hope Street, Castletown, Isle of Man, IM9 1AN as lead custodian and broker to the strategy.

CIL provides international dealing, custody, investment management and portfolio administration services. At the time of publication, CIL administered over $3.5bn of assets. CIL is a member of the London Stock Exchange and is licensed by the FSC. CIL is a member of the Capital International Group.

Participation Units Participation in the CFM BH Focused Growth Strategy will be sub-divided into standard participation units with a nominal value of £1 each. The Strategy Manager may issue additional units or cancel units as necessary to facilitate contributions to or withdrawals from the CFM BH Focused Growth Strategy.

Valuation The strategy will be valued on a mark to market basis quarterly on the last calendar day of each quarter. The Strategy Manager may at its absolute discretion determine additional valuation points on an ad hoc basis.

The strategy’s value will be determined by deducting the total liabilities from the total assets of the strategy. The value of the assets and liabilities of the strategy will be determined in accordance with CFML’s standard strategy valuation policy, which is available on request and may be published from time to time on CFML’s website.

Unit Pricing The net asset value per unit will be calculated by dividing the net asset value of the strategy by the total number of units participating in the strategy.

The Directors reserve the right to adjust the unit price on any valuation date to reflect the approximate true cost or value per unit associated with any investment or redemption from the strategy.

Introduction The CFM BH Focused Growth Index was formed by Capital Financial Markets Limited (“CFM”) in August 2010.

Operating Memorandum This Operating Memorandum details the basis by which the Index will be managed and how the index levels are calculated.

Reference Strategy The CFM BH Focused Growth Index is based on the performance of an underlying reference strategy called the CFM BH Focused Growth Strategy.

Strategy Manager The CFM BH Focused Growth Strategy is managed by Capital Financial Markets Limited (“CFML”) of Mill Court, Hope Street, Castletown, Isle of Man, IM9 1AN.

CFML is a specialist provider and issuer of contracts for difference and spread bet contracts. CFML is regulated by the Isle of Man Government Financial Supervision Commission (“FSC”) to conduct investment business.

CFML is a wholly owned subsidiary of Capital International Limited (“CIL”).

CIL is a member of the London Stock Exchange and is also licensed by the FSC.

CFML is a member of the Capital International Group.

Strategy Adviser The Strategy Manager has appointed Bank House Investment Management Limited (“Bank House”) of Bankhouse, 8 High Street, Prestbury, Cheltenham, Gloucestershire, GL52 3AS as the strategy investment adviser. Bank House is a wealth manager and financial adviser who provide financial planning and advice to a wide range of individuals, corporate and trust client. Bank House are regulated by the UK

Financial Services Authority (“FSA”).

CFM BH Focused

www.capital-iom.com

Publication of Unit Pricing 

The unit price of the strategy will be available on request from CFML. The unit price may also be published on CFML’s website. CFML will additionally endeavour to maintain pricing of the strategy on Bloomberg.

Contributions & Withdrawals The CFM BH Focused Growth Strategy is a private strategy operated by CFML. From time to time CFML may choose to contribute additional monies to or withdraw monies from the strategy at its absolute discretion.

Contribution and withdrawals may only be made on a valuation date. The amount of the contribution or withdrawal (after deduction of any charges) divided by the unit price on that valuation date will determine the number of units invested or disinvested.

The strategy may from time to time be subject to certain restrictions and minimum notice periods with respect to withdrawals.

Investment Objective To maximise returns and manage volatility through a focused growth investment strategy.

Base Currency Sterling

Management Approach The strategy is actively managed by the Strategy Manager on the advice of the Strategy Adviser in accordance with the investment strategy detailed below.

Investment Strategy The investment strategy of the CFM BH Focused Growth Strategy is to maintain exposure to a focused number of company shares and/or collective investment schemes and take advantage of other opportunistic investment strategies.

Leverage & Borrowing Powers The CFM BH Focused Growth Strategy will not utilise leverage or borrow against the assets of the strategy.

Restrictions The CFM BH Focused Growth Strategy may only maintain exposure to securities approved by the Strategy Adviser.

Risk Due to the focused nature of the investment strategy, there is likely to be higher levels of volatility and risk when compared to more traditional diversified equity strategies.

Fees, Charges and Expenses An initial Set-Up Fee of 1.5% will be deducted at outset.

An Investment Administration Fee of 0.7% per annum will be calculated and deducted quarterly.

The Set-Up Fee and the Investment Administration Fees are inclusive of the Strategy Advisers commission and all custody and administration charges.

All dealing and clearing costs, miscellaneous and legal costs will passed onto the strategy.

Capital Financial Markets Limited Mill Court Hope Street Castletown Isle of Man IM99 5XH

www.capital-iom.com/CFML T : +44 (0) 1624 828200 E: info@capital-iom.com

Contact Details

Capital International Limited and Capital Financial Markets Limited are members of the Capital International Group

Capital International is a member of the London Stock Exchange and is licensed by the Isle of Man Financial Supervision Commission Capital Financial Markets Limited is licensed by the Isle of Man Financial Supervision Commission

Registered Address: Mill Court, Hope Street, Castletown, Isle of Man, IM9 1AN

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