Trade Allocation Policy. The Manager’s trading policies are governed by the principle of fair allocation of investment opportunities. This allocation policy applies to all Bridging funds which are internally managed. Investments will be allocated on a basis believed to be fair and equitable; no fund will receive preferential treatment over any other. The portfolio management team will take steps to ensure that no fund will be systematically disadvantaged by the aggregation, placement, or allocation of investments. Principle of Fair Allocation of Investment Opportunities In order to ensure fairness in the allocation of investment opportunities among the funds managed and sub-advised by the Manager, the Manager will allocate investment opportunities in compliance with securities regulations and with consideration to the prime determinants of market exposure, cash availability and industry sector exposure and with regard to the suitability of such investments to each fund. In determining the suitability of each investment opportunity to a fund, consideration will be given to a number of factors, the most important being the fund’s investment objectives and strategies, existing portfolio composition and cash levels. Where an investment opportunity is suitable for two or more funds the Manager will allocate the opportunity equitably in order to ensure that funds have equal access to the same quality and quantity of investment opportunities, and in determining such allocations will consider a variety of factors and principles, including, but not limited to, the following: • Legal and regulatory restrictions. • The need within a particular fund for liquidity. • Other investment opportunities that may be available to a fund. • The duration of investments in a fund portfolio. • Each fund’s own investment restrictions. • Where allocation of an investment opportunity would be insufficient to make up a meaningful portion of an individual fund’s portfolio. • Transactions are allocated promptly • Cash availability The allocation for each participation must be documented by the compliance department. Taking into consideration the prime determinants described below and/or specific fund objectives and restrictions, certain investments will not be allocated across all funds. If any deviation from the investment trade allocation policy is noted, the credit committee is notified in writing. Any corrective action to be taken or follow-up explanations will be noted in writing. Prime Determinants: (i)...
Trade Allocation Policy. The Manager’s trading policies are governed by the principle of fair allocation of investment opportunities. This allocation policy applies to all investment funds which are internally managed by the Manager. Investments will be allocated on a basis believed to be fair and equitable; no fund will receive preferential treatment over any other. The portfolio management team will take steps to ensure that no fund will be systematically disadvantaged by the aggregation, placement, or allocation of investments.
Trade Allocation Policy. The Manager may not aggregate sales and purchase orders of securities placed with respect to the Account with similar orders being made simultaneously for other accounts managed by the Manager. It is the policy of the Manager that investments may not be allocated to one client account over another based on any of the following considerations:
Trade Allocation Policy. The Advisor’s trading policies are governed by the principle of fair allocation of investment opportunities. This allocation policy applies to all Bridging funds which are internally managed. Investments will be allocated on a basis believed to be fair and equitable; no fund will receive preferential treatment over any other. The portfolio management team will take steps to ensure that no fund will be systematically disadvantaged by the aggregation, placement, or allocation of investments.
