At the end, it all comes down to providing ATB s clients with products and services that fit their needs.

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Aldous Hart
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1 Business Ethics An integrated and efficient financial market requires market integrity. The fact that Amsterdam Trade Bank N.V. ( ATB or the Bank ) provides execution-only services, and does not facilitate personal investment advice of any kind, does not decrease its duty of fair treatment of customers, whereby full, fair and not-misleading information is provided to the client or prospect client at all times (the Duty of Care ). In the past few years the European financial market was enriched by number of Directives of the European Union, setting out basic principles safeguarding market integrity. These Directives were transposed to national legislation, namely in the Act on Financial Supervision ( WFT ) in the Netherlands. The background documents are: Markets in Financial Instruments Directive 2004 (MiFID) and all related documents (Level 2 and Level 3). Duty of Care The Duty of Care principle generates from English tort law meaning that an individual may be owed a duty of care by another, to ensure that they do not suffer any unreasonable harm or loss. If such a duty is found to be breached, a legal liability is imposed upon the duty-owner, to compensate the victim for any losses they incur. ATB considers the Duty of Care towards clients a crucial part of its business philosophy and handling in the best interest of client has always been a priority for ATB. Applying the Duty of Care means that ATB must be careful and responsible when providing services to clients and counterparties. ATB should always take the customer s interest into account, to the best of its ability. ATB applies Know Your Customer ( KYC ) controls as part of customer due diligence process to any new and/or existing client based on the client risk assessment and MIFID client classification. ATB has also processes in place to ensure on-going monitoring of client activity to be flexible in providing the services that the client most needs in changing circumstances. The Management Board of ATB (the Management Board ) is fully aware that caring for client also means anticipation of client needs. Any new product or service, and/or significant change to the existing one, is carefully assessed prior to the launch and in accordance with the Bank s New Product Approval Policy. The client s interest is paramount at all stages of the development of all ATB products and services. ATB understands the importance of providing full and up-to-date information to clients. At the end, it all comes down to providing ATB s clients with products and services that fit their needs. Amsterdam Trade Bank N.V. P.O. Box RC Amsterdam The Netherlands Phone +31 (0) Fax +31 (0) info@atbank.nl Chamber of Commerce Amsterdam VAT nr. NL B01 BIC ATBANL2A

2 Client Classification and Appropriateness test It is acknowledged that clients have different levels of knowledge and expertise dealing in investment products, therefore it is necessary to provide suitable customer protection to those least experienced. Client Classification results in three categories of clients under MiFID (predefined criteria): a. Eligible Counterparty b. Professional Client c. Retail Client 1 A. Eligible counterparties (the ECP ) are banks, credit institutions, insurance companies, and similar companies that can be presumed to have sufficient knowledge and understanding in dealing with investment products, and therefore get the least of consumer protection. B. Professional clients 2 (the Professionals ) are considered to have some experience and knowledge to be able to assess their risks and therefore get less regulatory protection than ECPs. C. Retail clients are those that do not qualify as ECPs or Professionals, and have the least understanding of investment services, and therefore should receive the highest level of regulatory protection. The Account Manager collects the necessary information to perform a client classification, and the final client classification is communicated to the client through a Client Classification Letter (the Classification Letter ). Clients have the right to request a change in classification, either an increase ( opt-up ) or a decrease ( opt-down ). Reclassification can only be initiated by the client in writing stipulating reasons for the request, especially if requesting an opt-up. A detailed process description and the process owners are described in ATB MiFID Procedures which constitute an integral part of ATB Conduct, Legal and Compliance Framework ( CLC Framework ). ATB will not provide MiFID products to non-professional parties (Retail classified clients). No opting down option is provided to a MiFID Professional classified client from its classification to a MiFID Retail classification. A client requesting an opting down will not be provided with MiFID related products. Pre-contractual information After classifying a client ATB will provide the client with ATB s Terms of Business (the Terms of Business ), containing general information on ATB, investment services/products it provides, plus rights and obligations of customers dealing with ATB in investment services. These Terms of Business constitute an agreement between the client and ATB, and are supplementary to other product specific agreements (e.g. ISDA). The pre-contractual information package also contains information on Terms of Business specifically related to MiFID related products, Order Execution Policy, Consent form (to be returned by the client to 1 It should be noted that retail here does not mean an individual per definition. 2 If it is not ECP and complies with two out of three quantitative criteria: i) balance sheet total of EUR 20 million or more; ii) net yearly turnover of EUR 40 million or more; iii) equity of EUR 2 million or more.

3 ATB before entering into MiFID related products/services), Conflict of Interest Policy, Information on Fees and Commissions and general product descriptions, the latter is only applicable for Retail Clients. The product description is a document in writing and contains a general description of the nature and risks of a financial instrument, aiming to assist a client in taking investment decisions. Standard product description documents are prepared by the Treasury department of ATB and updated from time to time if applicable. The description of risks must include, where relevant to the specific type of instrument concerned, the following information: - risks associated with that type of financial instrument, including an explanation of leverage and its effects, and the risk of losing the entire investment; - volatility of the price of such instruments and any limitations to the available market for such instruments; - fact that as a result of transactions in such instruments, the investor might assume financial commitments and other additional obligations, including contingent liabilities, that are additional to the cost of acquiring the instrument; and - any margin requirements or similar obligations applicable to instruments of that type. Product suitability matrix As various products and services offered by ATB require a different level of experience in dealing with investment services, and ATB deals with ECPs, Professionals and Retail Clients who require different level of customer protection, ATB decided to have a Product Suitability Matrix (the Matrix ). This Matrix contains an overview of products and services in scope of MIFID and offered by ATB per category of clients. Retail classified clients do not have access to MiFID products/services offered by ATB, as ATB believes that Retail clients cannot properly assess all risks associated with such products/services and therefore may act to their own disadvantage. The Matrix is available as attachment to ATB MIFID Procedures and will be updated from time to time if appropriate upon discretion of ATB. Chinese Walls A Chinese Wall is an information barrier system designed to prevent disclosing and/or sharing confidential information. It may consist of separation of business processes, physical separation, application of specific rules and/or software, etc. Dutch as well as European banking regulations require ATB to implement and demonstrate controls, ensuring that (confidential) information held in one area of the bank is not disclosed improperly to another unauthorised party. One method for doing this is to create internal Chinese Walls between relevant areas, to control way (confidential) information is treated and moved around. Chinese Walls help manage conflict of interests and protect confidentiality of client information. ATB applies this principle to selected processes in the Bank either on permanent or temporary basis. ATB physically places designated teams in separate office rooms. From a technical side, ATB limits access to stored client information on need-to-know basis.

4 Conflict of Interests Due to the wide range of financial services provided by ATB, the Bank may find itself in a situation where providing one client with a service it may materially damage interests of another client. ATB and its employees are committed to keeping up with the highest ethical standards, identifying and managing any (potential) conflicts of interest. The potential conflicts of interest include: those between ATB s clients with competing interests, client-client ; those between ATB s clients and ATB whether the respective interests in a particular outcome may be different; and those between the personal interests of ATB staff and ATB own interests or of ATB clients where those interests may be different. ATB has well established internal processes and procedures designed to manage potential conflicts of interest. These procedures are the subject to on-going monitoring and review, and include, but are not limited to: information barriers and Chinese Walls separate supervision and segregation of functions disclosure to client of potential conflict. ATB employees cannot act as a legal representative of a client or as an authorised signatory on any bank account of a client. Any transfer of funds between a client account and a bank account in the name of an employee is forbidden. In case an employee envisages a conflict of interest, he/she should make these considerations immediately known to CLC officer. An employee always has a conflict of interest, if: a) he/she personally has a material financial interest in a counterparty with which the Bank intends to enter into a transaction; b) he/she has a family law relationship (his/her spouse, registered partner or other life companion, foster child or relative by blood or marriage to the second degree) with a member of the management board of the counterparty with which ATB intends to enter into a transaction; c) he/she is a member of the management or supervisory board of, or holds similar office with, the counterparty with which ATB intends to enter into a transaction. Management of conflict of interests for members of the ATB Management and Supervisory Boards are covered within their respective internal charters. ATB employee is required to report to CLC officer any additional activity (pro-bono or paid) he/she performs in addition to main ATB function. CLC department evaluates whether the additional activity may be in conflict with ATB function and/or negatively impact ATB reputation. CLC department keeps a register of all reported activities and reviews it at least yearly.

5 Approval of Marketing Materials and External Communication Marketing and publicity on products and services as well as information published on the ATB website must be approved by CLC department prior to publishing. All information, including marketing communications, addressed by ATB to the client or a potential client shall be fair, clear and not misleading. Marketing communication shall be clearly identifiable as such. ATB puts great importance on having accurate and clear marketing information in an easy-toread language. Any advertisements and other marketing material must be in compliance with local standards and regulations. All public statements of facts must be checked for accuracy. ATB external communication will not include references to competitors or other companies directly by name unless the advertisement also promotes the third party product or service. Similarly, the trademarks of other companies should not be mentioned unless there is a legitimate need to do so. If mentioned, suitable acknowledgement of the trademark must be made. Dealing with media (newspapers, television, radio, publishers, etc.) requires the utmost sensitivity. Any information about ATB as a company must be handled with care to avoid misinterpretation or misuse. Therefore all media requests are forwarded to the ATB Management Board. Requests for official position statements on matters of particular significance or sensitivity such as litigation in which the Bank is involved must also be referred to the ATB Management Board even if the request is not from the media. Customer Complaints ATB values its customer s feedback, also in the form of a complaint, as it helps its business to improve. ATB would like to be recommended by its existing customers in their network as a reputable, business-oriented and client-friendly organisation to further build its business sustainably. Clients can submit complaints per telephone or to their usual contact person in ATB (e.g. Account Manager) or to the CLC Officer. ATB aims to solve the reported complaint straight away. The respective Account Manager or CLC Officer will promptly refer with the solution, and if is not available yet, client will be informed on expected resolution time. CLC department keeps a register of complaints, evaluates received complaints on a regular basis and report on it to the Management Board of ATB.

Contents FXORO MCA Intelifunds Ltd,

Contents FXORO MCA Intelifunds Ltd, Contents Client Classification... 2 Retail clients... 2 Professional Clients... 2 Eligible counterparties (ECP)... 3 Opt-down... 4 Opt-up... 4 Changes to professional client / eligible counterparty categorisation...