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POLICY FOR FAIRNESS IN ALLOCATION OF INVESTMENT OPPORTUNITIES

1. Teznia policy is to allocate equally among the client accounts, prorated for the dollar value, all the costs associated with block trades outside Teznia control. The procedure is to calculate these costs per dollar value of assets under Teznia management and charge them to client accounts.

2. In a case of a partial fill of requested trades, when the trades are blocked, the associated costs are allocated to client account in a similar manner as in section 1.

3. At Teznia the fairness policy applies to allocating “hot issues” and IPOs to client accounts. The policy is to allocate these investment opportunities to all client accounts prorated for the dollar value. The procedure is to calculate the amount of “hot issues” and IPOs per dollar amount and allocate the opportunities to client accounts accordingly.

4. Teznia policy in respect to block trades is to allocate equally on a prorated basis the costs of them among the client accounts participating in block trades. The fairness policy with full disclosure to clients is to ensure their total satisfaction.