Stockcube Research Limited - Policy on Independence

General

All investment research issued by Stockcube Research Ltd (“Stockcube”) is independent, impartial and objective.

Stockcube does not conduct any investment business on its own account or with or for its clients, other than the provision of research and taking and placing buy or sell orders for clients with stockbrokers through direct market access agreements.. Stockcube staff have no other responsibilities which could conflict with the interests of our investment research clients. Stockcube does not carry out any corporate finance business; does not sell or trade securities; and has no involvement in raising capital for corporate clients.

Stockcube has no other regulated or unregulated business activities which conflict with its provision of independent research.

Conduct of our Investment Analysts

All of Stockcube’s investment analysts are supervised by directors of the firm.

The remuneration structure for Stockcube’s analysts is not linked in any way to dealing or other activities which our customers carry out as a result of the independent research provided by the firm.

Our analysts are not permitted to be involved in any activities which could be seen as conflicting with our provision of investment research to our clients. No inducements offered by issuers, or others with a material interest in the subject matter of investment research, may be accepted by our investment analysts or directors of the firm.

No employee of Stockcube may carry out any personal account dealing which could create a conflict of interest which might affect the impartiality of Stockcube’s investment research. Any proposed personal account dealing by employees is subject to pre-approval by a director of Stockcube and no dealing which could create a conflict of interest between the employees of Stockcube and its customers is permitted. In addition, a prohibited list of securities is maintained. Stockcube itself does not hold securities on its own account. All outside business activities of employees are subject to prior approval by a director of the firm.

Our Research

The timing and manner of publication and distribution of investment research and of the communication of its substance must be approved in advance by a director of Stockcube. Before being issued, all research documents must be approved and signed-off by a director or senior analyst. No one outside Stockcube may comment on draft investment research before publication, other than, where necessary, to verify factual information.

Certain disclaimers may be included in our research where appropriate, for example for legal reasons. Stockcube's policy and procedures require investment research to be distributed in an appropriate manner.

Our investment research is published and distributed either in hard copy or on line. No employee may communicate the substance of any investment research, except in accordance with our policy of independence.

17 April 2007