credo capital plc - old mutual international capital plc for accounts of old mutual life ......

Credo Capital plc For accounts of Old Mutual Life Assurance Company (South Africa) Limited Isle of Man, Isle of Man branch Individual Name of Referrer: Branch: Name of Adviser:

Initialled by Plan Holder(s): _______________________ 2

Credo Capital plc Old Mutual Application Form Individual

Thank you for choosing to invest with Credo. Your application to open an account with us is made subject to the information contained in the relevant

Credo Capital plc (“Credo”) Terms of Business, applicable Schedule of Charges, the Letter of

Understanding dated 23 June 2015 issued by Old Mutual Life Assurance Company (South Africa) Limited

acting through its Isle of Man branch (“Old Mutual”), the Custody Services Agreement and this Application

Form, which, once completed, together form the agreement made between you and Credo. The applicable

Terms of Business, the Schedule of Charges and a copy of the Custody Services Agreement should be

retained for your personal records, while the Letter of Understanding, this Application Form and all the

requisite documents referred to in it should be completed, signed and returned to us at the following

address:

Client Services

Credo Capital plc

8-12 York Gate, 100 Marylebone Road

London NW1 5DX

United Kingdom

Tel: +44 (0)20 7968 8300

Fax: +44 (0)20 7968 8301

credogroup.com

Please note that incomplete information will unfortunately delay the opening of your account. As part of

anti-money laundering regulatory requirements Credo may require further evidence of your identity before

this Application Form can be processed (and thereafter). You hereby agree to hold Credo harmless and to

indemnify Credo and keep Credo indemnified against any loss:

arising as a result of Credo’s failure to process this form if such information has been requested and has

not been provided by you; and

suffered by Credo as a result of any breach of any representation, warranty, covenant or confirmation

by you in this Application Form or from your failure to disclose any relevant details or provide Credo with

all information requested by it or on its behalf.

In the case of delay or failure to provide satisfactory information, Credo may take such action (including

declining to accept an application) as it deems fit.

Should you require any assistance in completing this form please contact Client Services on

+44 (0)20 7968 8300 or at [email protected].

We look forward to welcoming you as a valued client.


Section I - Account Profile

Account Details

To be completed by Old Mutual

Name of Entity (on Credo system) Old Mutual Life Assurance Company (South Africa) Limited

Account Title (if different from the above) OMLACSA (OMIM) IA/IB/IC re __________________________________ (underlying policy number)

Type of Entity () Company

Nature of business Life Assurance

Global Intermediary Identification Number (GIIN), if applicable

Z2YIFL.00021.ME.833

Account Contact Details

To be completed by Old Mutual

Registered business address Old Mutual Life Assurance Company (South Africa) Limited King Edward Bay House, King Edward Road, Onchan, Isle of Man, IM99 1NU

Mailing address (if different from the above)

Old Mutual Life Assurance Company (South Africa) Limited, Isle of Man Branch King Edward Bay House, King Edward Road, Onchan, Isle of Man, IM99 1NU

Type of Mandate given to Credo - Only select ONE Mandate type.

To be completed by the Investment Portfolio Plan Holder(s) (the “Plan Holder(s)”) and where applicable the Financial Advisor

( ) Credo Model Portfolios - We have full discretion to manage investments selected for the Credo Model Portfolios Please indicate the type of investment portfolio you require:

Minimum Investment Amount (£/$) or %

( ) Equities ( ) Best Ideas Portfolio £100,000 / $150,000

( ) Dividend Growth Portfolio £100,000 / $150,000

( ) Fixed Income ( ) Income Plus Portfolios £100,000 / $150,000

( ) Mixed ( ) Multi-Asset Portfolios £100,000 / $150,000

Total £/$ (100%)

Please complete all sections, please use block letters and please tick the appropriate boxes. Where the space allocated for information is insufficient, please provide such information on a separate page and indicate the relevant section and subsection to which such information refers.



Please indicate how you made the decision to invest in one or more of the Credo Model Portfolios. ( ) I/We made my/our own decision ( ) My/Our financial advisor advised me/us* *WHERE ADVISED BY A FINANCIAL ADVISOR (“FA”):

Name of FA: __________________________________ Financial Services Board (“FSB”) regulatory number: __________________ Is the FA authorised by the FSB under Category 1 to advise on shares and/or bonds as well as any other Securities and Instruments (as defined by the FSB) that make up the chosen Credo Model Portfolio(s)? ( ) Yes ( ) No** ____________________________________________ Signature of FA **Where the answer is “No” you need to complete all of the Investment Objectives and Knowledge and Experience sections below.

( ) Credo advised me/us If you ticked this box you need to complete all of the Investment Objectives and Knowledge and Experience sections below.

( ) Discretionary - you give us full discretion to manage investments on your behalf as per your agreed investment proposal.

( ) Advisory Managed - we provide investment advice on your portfolio, but only act on your instructions.

( ) Advisory Dealing - we provide investment advice on a transaction by transaction basis, but only act on your instructions.

( ) Execution-Only - we act only on your instructions or those of the individual(s) named in the Letter of Authority provided by Old Mutual, if any. You do not expect to receive any advice or research from us.

Section II - Customer Profile

Personal Details

To be completed by the Plan Holder(s)

Plan Holder 1 Plan Holder 2

Title (Mr/Mrs/Miss/Ms/Other (please specify))

Surname

First Name

Marital Status

Date of Birth (day/month/year)

Place of Birth

Nationality

ID Number (SA residents)

Address

Home telephone number (including country and area code)

Work telephone number (including country and area code)

Mobile number

Fax number

Email address


Employment status (e.g. Full-time, Part-time, Self Employed, Retired, Unemployed, Student, don’t need to work).

Occupation (Please state the nature of self-employment (if applicable). If retired, your last occupation should be mentioned).

Employer’s name (where applicable)

Employer’s address (where applicable)

Are you a director of a listed company? If yes, please provide information. (If you require more space please use an additional page and attach it to this application).

Name of company Date of appointment Name of company Date of appointment

Financial Dependants

Name Date of Birth Relationship

Next of kin details

Do you (or did you previously) or does any member of your extended family (or did they previously) hold a position of high influence or authority in any Government or Government Body?

( ) Yes ( ) No ( ) Yes ( ) No

If “Yes”, when? If “Yes”, when?

If “Yes”, where? If “Yes”, where?

National Insurance Number (UK residents)

Are you a US citizen? ( ) Yes ( ) No ( ) Yes ( ) No

Do you have a US green card? ( ) Yes ( ) No ( ) Yes ( ) No

In which jurisdiction(s) are you resident for tax purposes?

Section III - Customer Financial & Investment Information

Financial Information - to be completed by the Plan Holder(s)

Please provide your global financial position below. In the case of a joint account please provide a consolidated global financial position. (Please state the currency if not in Sterling)

Total Annual Income (after tax) ( ) £0 - £20,000 ( ) £20,000 - £40,000 ( ) £40,000 - £60,000

( ) £60,000 - £80,000 ( ) £80,000 - £100,000 ( ) £100,000 +

Total Annual Expenditure £

Assets

Primary Residence £

Other Property £

Equities (i.e. Shares) £

Cash (investable) £

Fixed Income (i.e. Bonds) £

Other £ Specify:



Total Assets £

Liabilities £

Net Assets £

Are you paying interest on any short-term unsecured debt (e.g. credit cards, store credit)? (not required to be completed for Execution-Only Mandates)

( ) Yes ( ) No If “Yes”, how much?

Please indicate the currency in which you would like your portfolio to be reported to you

( ) Sterling ( ) US Dollar ( ) Euro ( ) Other: ________________

Please indicate the main currency in which you would like your portfolio to be invested

( ) Sterling ( ) US Dollar ( ) Euro ( ) Other: ________________

What is the initial investment amount? £

Do you anticipate requiring a withdrawal of more than 20% of your capital during the time horizon? (not required to be completed for Execution-Only Mandates)

( ) Yes ( ) No If “Yes”, what percentage? ___________%

Do you require a portion of your portfolio to remain in cash over the investment period? (not required to be completed for Execution-Only Mandates or Credo Model Portfolios)

( ) Yes ( ) No If “Yes”, what percentage? ___________%

Origin of the Funds to be sent to us - to be completed by Old MutualPlease state comprehensively the transaction(s)/economic event(s) that gave rise to the funds to be sent to us. Statements such as ‘earned income’, ‘sale of fixed property’, ‘inheritance’, etc. should be supported with details and evidenced, where possible or required by us.

Source of Funds Policy premium

Source of Wealth Policy premium

Name of Remitting Bank

Account Name

N.B. Please note that funds may only be received from an Account held in the same name as the name of the Account Holder(s) specified in Section I above.

Investment Objective

To be completed by the Plan Holder(s) if Credo has an Advisory or Discretionary mandate, or if Credo advised you to invest in one or more of the Credo Model Portfolios. If you have been advised by a financial advisor who has the necessary permissions you do NOT need to complete these sections.

Capacity for Risk Where Credo has the responsibility to determine what portfolio investment is suitable for you (i.e. where you are not advised by a Third Party), we need to make an assessment of your capacity for risk. For joint accounts, we will determine your joint capacity for risk on the basis of the main income generator’s (“MIG”) answers.

State of health of the Plan Holder/MIG?

( ) Excellent ( ) Good ( ) Fair ( ) Poor

What percentage of your total wealth, (excluding the value of your primary residence), are you investing with Credo?

( ) 0 - 10% ( ) 10 - 20% ( ) 20 - 30%

( ) 30 - 40% ( ) 40 - 50% ( ) 50 - 100%

What is the time horizon of your investment?

( ) > 10 years ( ) 7 - 10 years ( ) 5 - 7 years ( ) 3 - 5 years ( ) < 3 years

The time horizon is presumed to be a rolling time horizon (e.g. if you set a 5 year time horizon, after 2 years, we will still assume you are expecting us to invest for a further 5 years). Please inform us if you do not regard this as a rolling time horizon but as a finite period.


What is the purpose of your investment?

When do you anticipate retiring? Date: ____________ Number of years until then: ____________

Once you have retired, do you anticipate living off a capital portion of your investment?

( ) 0% ( ) 0 - 3% ( ) 3 - 5%

( ) 5 - 7% ( ) 7 - 10% ( ) 10% +

Do you require your normal living expenses to be supplemented by an annual amount of cash from your investment?

( ) 0% ( ) 0 - 3% ( ) 3 - 5%

( ) 5 - 7% ( ) 7 - 10% ( ) 10% +

Attitude to Risk Where Credo has the responsibility to determine what portfolio investment is suitable for you (i.e. where you are not advised by a Third Party), to enable us to determine your desired level of risk (or that of the MIG, where applicable) we also need to consider your attitude to risk. Please consider all three of these questions together and confirm which set of outcomes (in columns A to E below) best describes your attitude to risk. See Appendix 1 for an explanation of the terms set out below. Please note that Credo does not offer Capital Protection services. Capital Protection is merely listed below to gauge your attitude to risk.

Looking at the following graphs, what pattern of investment returns are you most comfortable with? NB: Usually the less volatile the return pattern, the lower the return over a longer investment cycle.

A

B

C

D

E

What average annual investment return would you hope that we can achieve for you over a 5 to 10 year period?

Base Rate

Consumer Price Index (“CPI”)

CPI + 2.5%

CPI + 5%

> CPI + 7%

Given that the higher the expected returns are, the higher the risk within the portfolio needs to be, please select the percentage value alongside that indicates the level that would concern you if your Credo portfolio decreased by in any given 12 month period?

-3% -8% -10% -15% -20%

Risk Profile

( ) Capital Protection

( ) Cautious

( ) Moderate NB: You should only tick this box if you tick the ‘Moderate’, ‘Medium-High’ or ‘Very High’ box in the Knowledge and Experience section below.

( ) Growth NB: You should only tick this box if you tick the ‘Moderate’, ‘Medium-High’ or ‘Very High’ box in the Knowledge and Experience section below.

( ) AdventurousNB: You should only tick this box if you tick the ‘Medium-High’ or ‘Very High’ box in the Knowledge and Experience section below.

Risk Profile given to Credo. Only needs to be completed where mandate is Execution Only

Risk Profile

( ) Capital Protection

( ) Cautious

( ) Moderate NB: You should only tick this box if you tick the ‘Moderate’, ‘Medium-High’ or ‘Very High’ box in the Knowledge and Experience section below.

( ) Growth NB: You should only tick this box if you tick the ‘Moderate’, ‘Medium-High’ or ‘Very High’ box in the Knowledge and Experience section below.

( ) AdventurousNB: You should only tick this box if you tick the ‘Medium-High’ or ‘Very High’ box in the Knowledge and Experience section below.

Investment Restrictions Depending on the level of knowledge and experience you specify below, please note below any investment restrictions you may have.



Non-Mainstream Pooled Investments (“NMPIs”) such as hedge funds, private equity funds and property funds (i.e. that are not authorised by the Financial Conduct Authority (“FCA”)):

Where the Mandate is Execution-Only, may we promote NMPIs to you? ( ) Yes ( ) No

Where the Mandate is Advisory can we recommend NMPIs to you, if we believe it to be suitable? If “Yes”, you will need to complete an Investor Statement. Your Relationship Manager will provide you with this prior to any such investment.

( ) Yes ( ) No

Where the Mandate is Discretionary can we invest in NMPIs on your behalf, if we believe it to be suitable?

( ) Yes ( ) No

Any applicant who has ticked “Yes” must also complete the NMPI Warning Acknowledgement Form attached to this Application Form.

Please indicate below any further investment limits or restrictions that you may wish to apply to your Account with us (e.g. no tobacco shares, no emerging markets securities, etc.).

Section IV - Background Information

Knowledge and Experience

To be completed by the Plan Holder(s) if Advisory or Discretionary, or if Credo advised you to invest in one or more of the Credo Model Portfolios. If you have been advised by a financial advisor who has the necessary permissions you do NOT need to complete these sections.

You (or for joint accounts, the MIG) need(s) to have at least a moderate level of investment knowledge and experience about the investments you hold/wish to hold in each of the relevant asset classes below. If you have given us an Execution-Only mandate and you wish to invest in the complex products listed below, we need to determine that you have the necessary knowledge and experience for such investments to be appropriate for you. To assist you to achieve this, please review the Credo educational document entitled ‘Can Risk Education Deliver Opportunity’ (the “Education Document”).

Knowledge + Experience

Low (little or no knowledge/experience of investments)

Moderate (reasonable knowledge/experience of investments)

Medium-High (reasonably extensive investment knowledge/experience)

Very High (extensive investment knowledge/ experience)

Listed Equities (not required to be completed for Execution-Only Mandates)

Fixed Income (not required to be completed for Execution-Only Mandates)

NMPIs (e.g. Hedge Funds, Private Equity Funds and Property Funds)

For each, please describe how you acquired your knowledge/experience

Listed Equities:

Fixed Income:

NMPIs:

NMPIs

Are you already a participant in any NMPI and if so, how long have you been invested?

( ) Yes ( ) No

If “Yes”, please give details of the NMPI:

Have you ever been a participant in any NMPIs and if so, when?

( ) Yes ( ) No

If “Yes”, please give details:

Are you aware of the risks of investing in such structures?

( ) Yes ( ) No


Client Categorisation as an Elective Professional Client Have you carried out transactions on an Execution-Only or Advisory basis, in significant size, on a relevant market at an average frequency of 10 per quarter over the previous four quarters?

( ) Yes ( ) No

Does the cumulative value of your portfolio(s) (held at Credo AND elsewhere) exceed €500,000 (including cash deposits and financial instruments)?

( ) Yes ( ) No

Have you worked in the financial sector for at least one year in a professional position which requires knowledge of transactions or services of the same nature as those that will be provided by Credo?

( ) Yes ( ) No

Section V - Authorization and Consent

Third Party Authority - to be completed by Old Mutual

( ) Please tick if you wish to give the Plan Holder(s) or another person(s) (e.g. the Plan Holder’s(s’) investment advisor) (a “Third Party”) authority to give us trading instructions on this Account. Please ensure that a Letter of Authority is provided.

Section VI - Supplementary Documentation

Documents Required for Third Parties, if any

A) Name Identification - if the Third Party being appointed is an individual (including the Plan Holder(s))

Please provide the original or a certified copy* of one of the documents listed below. The copy must show your passport/identity number, your name, your photo, the expiry date and any extension pages.

Current Passport

National Identity Card (that includes an expiry date) N.B. South African and UK Identity cards are NOT acceptable

Driving licence (photo cards only)

Residential Address Identification

Please provide the original or a certified copy* of one of the documents listed below (which must be less than 3 months old).

Bank or Building Society Statement Utility Bill (mobile phone bills are NOT acceptable)

Notice of Tax Coding

Credit or Debit Card Statement Mortgage Statement Council Tax Demand

N.B. This must be addressed to the individual at the residential address. P.O. Box addresses are NOT acceptable.

B) If the Third Party being appointed is a corporate entity

Please provide the original or a certified copy* of one of the documents listed below.

Certificate of Incorporation

Certificate of Name Change (if applicable)

Memorandum and Articles of Association

List of the shareholders extracted from company register and for each shareholder who owns or controls (directly or indirectly) 25% or more please provide identification documents as applicable (i.e. for a corporate entity please provide as per this List B, for a trust please provide the Trust Deed,

list of Trustees plus each Trustee’s identification documents as per List A above, the Authorised Signatory List plus each signatory’s identification documents as per List A above).

Evidence of registered address

List of directors

Authorised Signatory list and for each authorised signatory please provide identification documents as per List A above



C) If the Third Party being appointed is a corporate entity which is a financial institution in the UK, EEA or a jurisdiction of equivalent status

Please provide the original or a certified copy* of one of the documents listed below.

Evidence of licence or registration with regulatory authority

Authorised Signatory list and for each authorised signatory please provide identification documents as per List A above

(*) Original and Certified Copy Documents Certified copies of documents are acceptable. However, these must be certified with words that indicate that the original document has been seen and that the copy is a true copy of the original, by one of the following: a regulated person, government official, Commissioner of Oaths, Notary Public, Justice of the Peace, Minister of Religion, teacher, lawyer, banker, or accountant. Self-certification is not acceptable. Certification must include the certifier’s name, certifying capacity, date of certification, contact details (where this is not obvious) and be independent of the party concerned.

Further Documents Required

A W-8BEN-E Form** is attached. ALL applicants who are non-US persons must complete the W-8BEN-E form. We are required to lodge this form with the IRS in case there is any dealing in US securities and/or US denominated securities.

An NMPI Warning Acknowledgement Form is also attached. This is to be completed ONLY by applicants who indicated their interest in NMPIs above.

Pursuant to the US Foreign Account Tax Compliance Act (“FATCA”) the Plan Holder is required to provide us with its FATCA status. Please complete the attached FATCA Self-Certification form.

(**) Documents to be completed for the IRS Refer to the IRS website (www.irs.gov) should you require guidance in this regard.

Section VII - Miscellaneous

Document Checklist

Once you have completed this Application Form and read the applicable Terms of Business, please use this checklist to ensure that you have enclosed all documentation required.

( ) This original Application Form duly completed, signed and dated

( ) Original or certified copies of documents referred to above

( ) Original W-8BEN-E Form

( ) Original NMPI Risk Warning Acknowledgement Form (if applicable)

( ) FATCA Self-Certification

Section VIII - Declarations and Signatures

To be executed by Old Mutual and the Plan Holder(s)

I/We confirm that to the best of my/our knowledge the details provided in this application form are correct.

I/We acknowledge and agree that you rely on this information to: a) Categorise me/us correctly as a retail or professional customer for the purposes of the Financial Services and Markets Act 2000

and the rules of the FCA; b) Identify properly and recommend suitable investments to me/us where you provide a Discretionary or Advisory service to me/us;

and c) Consider the appropriateness of transactions in complex products where you provide Execution-Only services.

We, Old Mutual hereby warrant and represent that we have instructions to open the account with Credo from the Plan Holder(s).

I/We have read and agree to Credo’s relevant Terms of Business together with Credo’s conflicts of interest policy and order execution policy.

I/We hereby agree to be bound by Credo’s published Schedule of Charges (as amended from time to time) and any other fees or charges which may be payable by me/us and hereby give Credo permission to debit my/our account directly with such fees and/or charges which are due and payable.

I/We undertake to advise Credo of any changes in my/our circumstances that may lead to a change in my/our risk profile or a change in any of our relevant details and I/we indemnify Credo and hold it harmless for any loss I/we may suffer as a result of my/our failure to do so.


I/We confirm that I/we have read and understood the risk profile explanations set out in Appendix 1 and, where applicable, the relevant explanations set out in the Education Document.

I/We represent and warrant that I/we are not a US person for the purposes of US Federal income tax and that I/we are not acting for, or on behalf of a US person. I/We understand that a false statement or misrepresentation of tax status by a US person could lead to penalties under US law. I/We agree that if my/our tax status changes or I/we become a US citizen or a resident, I/we must notify you within 30 days.

We, Old Mutual represent and warrant that we are not a US person for the purposes of US Federal income tax and that we are not acting for, or on behalf of, a US person. We understand that a false statement or misrepresentation of tax status by a US person could lead to penalties under US law. We agree that if our tax status changes or we become a US citizen or a resident, we must notify you within 30 days. Signed by the Plan Holder(s) _______________________________ _______________________________ ___________________

Name Signature Date _______________________________ _______________________________ ___________________

Name Signature Date Signed on behalf of Old Mutual Life Assurance Company (South Africa) Limited, Isle of Man Branch:

Old Mutual signs this as account holder and legal owner of the assets. Old Mutual is not party to any discretionary investment mandates/agreements with the Plan Holder(s) and/or his/their agent.

_______________________________ _______________________________ ___________________

Authorised Signatory Signature Date _______________________________ _______________________________ ___________________

Authorised Signatory Signature Date



NMPI Risk Warning Acknowledgement Form To: Credo Capital plc

a) We hereby confirm that:

(i) you may promote NMPIs to us (where the Mandate is Execution-Only); or

(ii) you may recommend and give advice to us in connection with NMPIs, where you believe an investment in an NMPI is suitable

for us (where the Mandate is Advisory); or

(iii) you may invest in NMPIs on our behalf, where you believe an investment in an NMPI is suitable for us (where the Mandate is

Discretionary),

in accordance with the terms set out in your Standard Terms of Business.

b) We understand that where you invest on our behalf or give advice in connection with NMPIs, we will not have the right to complain

to the Financial Ombudsman or have a right to compensation from the Financial Services Compensation Scheme.

c) We understand that:

(i) where you give advice in connection with NMPIs, we may not invest in an NMPI; or

(ii) where you have a Discretionary Mandate you may not invest in NMPIs on our behalf,

unless we have provided you with an Investor Statement (in the format prescribed and which our Relationship Manager will provide to

us) which is no older than 12 months old.

d) We have read and understood the NMPI Risk Warning Notice set out in the Standard Terms of Business.

Account Holder(s) Name(s): __________________________________________________________________________________

Signature(s) of the named Account Holder(s): ___________________________________________________________________

Date: _____________________________________________________________________________________________________

FATCA Self-Certification

FATCA Status

Please select the FATCA status of the entity (tick one box only).

( ) Specified US person Enter US Taxpayer Identification Number (TIN):

( ) US Person, but not a specified US person

( ) Partner Jurisdiction FI Enter Global Intermediary Identification Number (GIIN): ___________________________________________

( ) Participating FFI

( ) Registered Deemed-Compliant FFI

( ) Certified Deemed Compliant FFI

( ) Exempt Beneficial Owner

( ) Excepted FFI

( ) Non-participating FFI

( ) Active NFFE

( ) Passive NFFE

If FATCA status is “Passive NFFE”, please complete the following:

( ) I certify that the entity does NOT have a Controlling Person who is a US citizen or resident.

( ) I certify that the entity has provided an attachment to this form that contains the name, address and TIN of each Controlling Person of the NFFE.


Appendix 1 - Risk Profiles Every investor is unique. It is only once we have a thorough understanding of your reasons for investment, your expectations,

circumstances and attitudes to risk that we are able to determine how to meet your needs. Different levels of return involve different

levels of risk. It is the balance between these two factors which determines the construction of your portfolio. All investments are

subject to some form of risk. These risks vary in degree and you as an investor will have different levels of concern about each risk.

From those focused on protecting their money, to those willing to incur short-term losses for higher returns over the longer term, our

portfolios cater for all objectives, save that we do not offer investments or model portfolios that would be suitable for clients who are

looking for “Capital Protection” only, i.e. investors who want a portfolio with similar characteristics to that of a cash account.

Investment risk refers to the degree of uncertainty about the return from an investment. The higher the return expectation, the greater

the risk of a loss as a result of increased investment volatility. Investment risk can manifest itself in a variety of ways, e.g. investments

may fluctuate in value due to government policies, the economic outlook and the movements of financial markets. Moreover, some

assets may take time to sell. If these risks are high, a longer time horizon would be desirable to increase the probability that the level

of return targeted can be met. Credo’s assessment of the risk of an investment takes into account various risk factors with an aim to

protect and enhance our clients' wealth.

Cautious

You prefer lower risk investments but are willing to accept small downside risk to your capital in order to achieve a higher potential

return than cash deposits. Your holdings will include investment grade bonds.

Moderate

You are prepared to take a moderate amount of capital risk but with a lower allocation to growth assets and a focus on minimising

potential downside. There will be some exposure to higher yielding bonds and low risk equities.

Growth

The focus of your portfolio is on potential growth of capital over the long term. The portfolio accepts short term volatility as a trade off

for higher potential returns. A substantial proportion of your portfolio will be allocated to riskier assets - this can take various forms, for

example, the whole portfolio may be invested in a diversified basket of large capitalisation equities listed in developed markets, as well

as one which includes only a portion allocated to a similar basket of equities, with the rest of the portfolio allocated to a mixture of

investments (some of which may in fact be higher risk, such as small capitalisation and/or emerging market equities and others that

are lower risk, such as investment grade bonds).

Adventurous

This is the most flexible profile. You accept significant risk to increase your return-generating potential. Your portfolio may be subject

to substantial short term volatility.



Appendix 2 - Can Risk Education Deliver Opportunity?

Introduction

Investment Risk

Asset Class Risks

Cash

Fixed Income

Equities

Property

Alternatives

Credo’s Approach to Risk

Risk Profiles

Risk Management

Introduction Investment risk can be defined as the chance that the actual return of an investment will differ from its expected return. It includes the

possibility of losing some or all of the original investment.

At Credo, we also consider alternative definitions of investment risk (such as standard deviations of returns and other mathematical

concepts) and some of these are taken into account in various stages of our investment process. Having said that, our main focus is

typically on capital preservation and we therefore focus first and foremost on protecting you from the risk of not being able to achieve

this over the course of your investment horizon.

Investment Risk The common types of risks that may occur when investing are as follows:

Market Risk/Systematic Risk

The possibility for an investor to experience losses due to factors that affect the overall performance of the financial markets. Market risk,

also called "systematic risk," cannot be eliminated through diversification, though it can be hedged against. The risk that a major natural

disaster will cause a decline in the market as a whole is an example of market risk. Other sources of market risk include recessions,

political turmoil, changes in interest rates and terrorist attacks.

Interest Rate Changes

The risk that an investment's value will change due to a change in the absolute level of interest rates, in the spread between two rates,

in the shape of the yield curve, or in any other interest rate relationship. (The yield curve is a curve showing several yields or interest

rates across different contract lengths (2 months, 2 years, 20 years, etc.) for a similar debt contract. The curve shows the relation

between the (level of) interest rate (that is, the cost of borrowing) and the time to maturity, known as the "term", of the debt for a given

borrower in a given currency. Such changes usually affect securities inversely i.e. if interest rates rise, the price of a bond will fall. This

effect can be reduced by diversifying (investing in fixed-income securities with different durations) or hedging (e.g. through an interest

rate swap).

Inflation

This is the risk that inflation will undermine the performance of your investment. Looking at results without taking inflation into account

gives the “nominal” return. The more relevant value is the growth of your purchasing power (which takes inflation into account) and is

accordingly referred to as the “real” return.


Deflation

This refers to a general decline in prices, often caused by a reduction in the supply of money or credit. Deflation can also be caused

by a decrease in government, personal or investment spending. The opposite of inflation, deflation has the side effect of increased

unemployment since there is a lower level of demand in the economy, which can lead to an economic depression. Central banks

attempt to stop severe deflation, along with severe inflation, in an attempt to keep excessive drops in prices to a minimum. The

decline in the prices of assets is often known as Asset Deflation.

Liquidity

This is also known as "marketability", the degree to which an asset or security can be bought or sold in the market without affecting

the asset's price. Liquidity is characterized by a high level of trading activity. Assets that can be easily bought or sold are known as

liquid assets as are assets that have the ability to be converted to cash quickly.

Sector/Industry exposure

The performance of the economy or market risk can have a significant impact on the success of the companies operating in it. Some sectors

are more sensitive to changes in the economy and this can have a disproportionate impact on companies operating in those sectors.

Debt or Gearing

Investment Trusts and other collective investments can be geared by borrowing money to invest and therefore attempt to magnify the

potential returns. This can also magnify the losses that occur.

Overseas exposure

Investing in overseas markets involves additional risks as the degree of investor protection and quality of accounting disclosures can

come at a lower standard than that expected in home markets. Changes in legislation and/or political instability can also make it

difficult to repatriate your investment back to the country of origin.

Tax

Changes in tax regimes can also adversely affect the income and value of your investment.

Asset Class Risks

Cash

Cash deposits such as bank or building society savings accounts offer capital security (up to £85,000 - see below) and a rate of

interest, usually variable but in some cases fixed. The Financial Services Compensation Scheme in the UK guarantees 100% of the

first £85,000 of deposits in the event of the bank or building society’s insolvency.

Every investor has a different set of requirements for cash. Accordingly, the individual investor is best placed to assess how much of

their portfolio they need in cash.

Risk Analysis of Cash

If you are unwilling to take any risk with your money you would be better off depositing your cash into a savings account. The downside is that

long-term returns tend to be lower than those from other asset classes, which means they are disproportionately affected by inflation.

If inflation is 3% and the interest rate on your savings is 1%, in a few years’ time, your money will buy less than it does now. The

opposite can happen, of course, where interest rates are higher than inflation - and that works in your favour.

Fixed Income

What is a Fixed Interest Security?

A bond, Treasury bill, Guaranteed Investment Certificate (GIC), mortgage, preferred share and similar instruments which traditionally

have the attributes below:

Debt instrument issued by a government, corporation or other entity to finance and expand their operations.

Provide you with a return in the form of fixed periodic payments and eventual return of the initial capital (also called the “principal”)

invested, at maturity.

The purchase of a fixed-income product represents a loan by you to the issuer.

Secure, low-risk way to generate a steady flow of income. As long as they are held to maturity, fixed-income securities will provide a

guaranteed return on your investment, with payments known in advance.



During the life of the loan, the debt instrument can be traded on the stock market. If the level of income looks attractive relative to

current interest rates (also taking into account the risk associated with the issuer), the price of the stock is likely to rise. Conversely, if

the level of income looks unattractive, or concerns increase about the possibility of the issuer defaulting, the price will fall. This can

give rise to pricing anomalies.

Government Bonds/Gilts

Usually issued via an auction, and once issued are traded on the stock exchange like shares.

If bought ‘above par’ (i.e. at a price above their redemption value), you will suffer a capital loss if you hold the bond to redemption.

If bought ‘below par’ and are held to redemption, a capital gain will be made.

The name of a government bond tells you all you need to know e.g.: 5% Treasury Stock 2015

5% - indicates that the bond pays interest (a “coupon”) of £5 for every £100 of nominal stock held.

Treasury - indicates that the bond is a loan to the UK Government.

2015 - indicates that the bond will be redeemed by the UK Government in 2015.

Risk Analysis of Government Bonds/Gilts

The main risk with government bonds is the possibility that a government might default on its debt. This can be more of a threat with

emerging market bonds, compared to, say, UK Government bonds which are also known as gilts (since the certificate was once gilt-

edged). The UK Government’s credit rating has, however, been under review by rating agencies recently, with some suggesting that

the possibility of default is not as remote as previously believed.

Gilts are less likely to default than corporate bonds and therefore they don't have to pay such high returns to attract investors.

Some gilts are index linked, which means their nominal value, and therefore investors’ capital and interest rises in line with inflation.

These tend to offer lower income.

Whilst gilts are much less volatile than shares, their value can fall as well as rise and you could get back less than you invest.

The two main factors which influence their price are interest rates and inflation.

Interest rates represent the ‘risk-free’ return available elsewhere, so a rise in interest rates makes gilts relatively less attractive and

vice versa.

Inflation erodes the value of both the interest and redemption payments from gilts, and therefore a rise in inflation (or expected

inflation) will cause gilt prices to fall.

Long-dated gilts (those with 15 years or more to run), are generally considered to be more sensitive to changes in interest rates and inflation,

as investors are exposed to the higher/lower returns for a longer period.

Short-dated gilts are defined as those with fewer than seven years until redemption.

Corporate Bonds

Fixed interest securities issued by companies to raise money.

Issued at a nominal or “par” value, and the issuing company promises to repay this on a set redemption date and to pay a fixed rate of

interest (the “coupon”) on the nominal value until redemption.

Returns are known if held for the full term and the company honours its obligations.

Certain bonds have call options (at the discretion of the company) or put options (right given to the bondholders) attached to the bond issue.

A callable bond gives the issuer of the bond the right to redeem the bond at some point before the bond reaches its maturity date. In

other words, on the call date(s), the issuer has the right, but importantly not the obligation, to buy back the bonds from the

bondholders at a pre-defined call price.

The holder of a put option in respect of a bond has the right, but not the obligation, to demand early repayment of the principal. The

put option is exercisable on one or more specified dates. The repurchase price is set at the time of issue, and is usually at par value.


Bond Credit Ratings

“Investment-grade” bonds are issued by companies with a good credit rating (e.g. Apple, Coca Cola), while those with a lower credit rating

are “sub-investment grade” or “high-yield.” The bond credit rating reflects the perceived credit worthiness of a corporate's debt issue.

Ratings are assigned by credit rating agencies such as Moody's, Standard & Poor's and Fitch Ratings and are meant to capture and

categorise credit risk.

Bonds are given letter designations (such as AAA, B, CC) which represent the perceived quality of a bond. The lowest Investment

grade rating is BBB-/Baa3 and anything below that is considered high-yield. Bonds with lower ratings tend to pay more interest to

attract investors and compensate them for the higher risk. They are often more volatile than investment grade bonds, but usually less

so than comparable shares and prices which tend to be influenced more by the profits of the issuing company than by interest rates.

Risk Analysis of Corporate bonds

Since bonds are tradable instruments often listed on major exchanges, investors need not hold them until the maturity date. Thus, the

market price of a bond will fluctuate between the bond’s issue and its maturity date.

When a bond is first issued, it is generally sold at par, which is the face value of the bond (e.g. $1,000 or £1,000). The par value is the

principal, which is received at the end of the bond’s term. After issue, bonds are tradeable in the secondary market almost always for

either more (premium) or less (discount) than par, because interest rates change continuously.

There is no protection scheme in place for corporate bonds - their security is entirely dependent on the company which has issued them.

Default Risk

Default risk is the risk that the company will be unable to make interest or principal payments when they become due. If these

payments are not made according to the agreements in the bond documentation, the issuer may default.

When compared to government bonds, corporate bonds generally have a higher risk of default. This risk largely depends on the

specifics of the particular company issuing the bond (profitability, solvency, balance sheet strength etc.), how easily the company will

be able to re-finance, reliance on the wholesale market, retail deposits (for financial companies), banking relationships and the current

market conditions in the company’s sector and country of operation.

Understanding where the bond sits in the company’s capital structure is paramount in assessing default risk.

From a risk perspective, it is preferable that the debts owed to an investor rank as high up as possible in the company’s capital

structure hierarchy. Once an entity declares insolvency and begins asset liquidation, the bondholders/creditors at the top of the

structure get paid first (after secured creditors), whereas the equity holders at the bottom of the hierarchy get paid last (if there are any

asset proceeds remaining to be distributed).

A general ranking, from top to bottom, of the major security categories in the capital structure are as follows:

1. Senior bonds

2. Subordinated bonds

3. Convertible bonds

4. Preferred stocks

5. Common stocks/equity

Senior Bonds

Senior bonds are debt that takes priority over other unsecured or otherwise more "junior" debt owed by the issuer;

Senior debt has greater seniority in the issuer's capital structure than subordinated debt;

It is a class of corporate debt that has priority with respect to interest and principal over other classes of debt and over all classes

of equity by the same issuer.



Subordinated Bonds

Subordinated bonds carry less seniority in the "pecking order" of the company's balance sheet;

In good times, this will make little difference, but if the issuer starts to suffer financial problems, the coupon payment on certain

classes of subordinated debt may be waived (see below);

In addition, if the issuer is forced into liquidation, subordinated bondholders will only be paid out once all senior debt has been repaid

(Note: subordinated holders will, however, rank ahead of equity holders);

The ranking is as follows (with guidelines of typical features):

1. Senior Debt

2. Lower Tier 2 Subordinated: No coupon deferral. The next best after senior debt

3. Upper Tier 2 Subordinated: Coupon deferral, but cumulative i.e. in the event that the coupon is not paid when due, the amount of

the coupon is added to the capital and increases the value of the bond

4. Tier 1 Subordinated: Coupon deferral, non-cumulative

Interest Rate Risk

If general interest rates rise, bond yields look less attractive in light of the extra risk that they carry and although the bond prices will

fall, conversely the bond yield goes up, i.e. when rates decline, fixed-coupon bond prices rise.

This means that when you buy a bond, you are typically guaranteed a "fixed income" stream, in the form of regular coupon payments.

If you purchase one investment with a fixed payment and then later on you buy a different investment promising a higher rate, the first

investment you bought would not be worth as much in comparison with the later investment.

You will still get back the promised “par” amount when your bond matures, but in the meantime, you will receive "below" market fixed

income payments. You lock in the interest rate on the bond with your initial purchase and at the point in time when you assess the

investment that fixed rate will look more or less appealing compared to other rates at the relevant time.

It also works in the other direction. If rates fall and you can't buy another investment with a coupon paying as much as the coupons

you are already receiving, your older investment would be worth more than those you buy with lower coupon rates. In other words, its

value would rise, compared to currently available alternatives.

The longer the period to a bond’s maturity, the greater its sensitivity to interest-rate risk. Therefore, longer dated bonds are more

volatile than shorter dated bonds and higher coupon bonds tend to be less volatile than low coupon bonds.

Ways to mitigate interest rate risk - buy short dated, higher coupon bonds.

Inflation Risk

Inflation is a significant risk for bond investors, as bonds lock in a fixed return for a specified period and thus, as inflation rates rise, the

real return to investors diminishes. In a deflationary environment, bonds rally significantly.

Ways to mitigate inflation risk - buy inflation linked bonds (these bonds offer little value at present) or floating rate bonds, where

coupons are linked to market interest rates (which in a normalised environment rise with inflation).

Liquidity Risk

The risk that investors may have difficulty finding a buyer when they want to sell and may be forced to sell at a significant discount to

market value. Liquidity risk is greater for thinly traded securities, such as lower-rated bonds, bonds that were part of a small issue,

bonds that have recently had their credit rating downgraded or bonds sold by an infrequent issuer.

Market Risk

The risk that the bond market as a whole would decline, bringing the value of individual bonds down with it, regardless of their

fundamental characteristics.


Currency Risk

Where a corporate issues bonds in a foreign currency, there is a risk that the corporate may be unable to refinance or repay the

foreign debt should there be a decrease in the exchange rate between the domestic currency of the corporate and the foreign

currency that the bond was issued in.

Equities Equities are shares of a company, also known as "stocks."

When you buy shares of a company, you're purchasing an ownership interest in that company.

Shareholders expect to receive dividends from the company when the company achieves profits.

Companies issue two basic types of stock: common and preferred shares. Shares can either be bought from the company when it first

offers shares to the public (known as an Initial Public Offering or IPO) or on the stock market once launched.

Risk Analysis of Ordinary Shares

Shares have the potential to significantly grow in value, but are usually more volatile than other asset classes and are often more

suitable for longer investing time horizons.

There are a number of ways you can minimise the risk of investing in ordinary shares:

Spread the risk - the more companies you invest in, the more you spread the risk. If you were to invest equally in shares in four

companies and one of them did particularly badly, that would adversely affect 25% of your money.

Invest in funds - if you had invested in a fund that covered 100 companies equally and one company did not perform well, only 1%

of your investment would be affected.

Sector spread - if you spread your investment over different sectors that may also act as a hedge against each other. If you limit

your investment to a single industry sector, say mining, or a geographical region, e.g. South Africa, your returns will grow quickly

when those areas are booming, but will also be more quickly affected by the negative effects of any economic downturn.

Market Risk

Share prices are influenced by levels of supply and demand:

High demand and low supply - the price will rise,

Low demand and high supply - the price will fall.

There are many reasons why the supply and demand for shares changes. These may be:

Specifically related to the company concerned such as expected profits, takeovers, research reports, resignation or appointment

of new directors, expansion or new contracts;

Wider factors such as legal and environmental issues, interest rates, oil prices, political reasons, competitors’ performance, etc.

If a company becomes insolvent, their shares become worthless and any capital invested is lost.

The shares in companies that have share prices that regularly go up and down by large amounts are regarded as being volatile

shares and the companies are considered to be more risky than companies whose share prices tend to be rather stable. This is

because there is an increased chance that capital could be lost when buying shares in such companies.

Share Indices

Indices include a group of shares gathered together so that their collective performance can easily be identified. These can include

both UK and overseas traded shares.

The main indices in the UK market are as follows:

FTSE All Share index includes all eligible companies listed on the London Stock Exchange (“LSE”). The movement on this index

reflects the whole market.



FTSE 100 index includes the 100 companies whose share capital has the highest value on the LSE. These shares are considered to

be towards the lower end of the risk spectrum because these companies usually have a long trading history, are well managed,

subject to external scrutiny and have the resources to overcome most problems they may encounter.

FTSE 250 index includes the next 250 companies by value and below that is the FTSE Small Cap Index. Smaller company shares are

considered more risky because there can be difficulties in buying and selling their shares, particularly in large numbers, they can also

have relatively short trading histories, a low level of capital resources available to overcome problems, and are subject to much less

external scrutiny.

Market Sectors

Shares of companies are grouped by the type of business the company does, rather than the size of the company. The differing types

of businesses are broken down into sectors. Traditionally there has been some consistency between companies in the same sector,

for example bank share prices tend to all move in the same direction when interest rate changes are announced. Furthermore some

sectors have in the past tended to act differently when compared to others, for example the utility sector tends to pay higher levels of

dividends and is considered to be a suitable investment for those seeking income, whereas the technology sector tends not to pay

dividends so is not suitable for such an investor.

Preference Shares

These are a special type of share which aim to pay a fixed dividend each year. For this reason they behave like a cross between a

share and a corporate bond. Preference shares may be convertible, which means shareholders have the option of converting them

into ordinary shares.

Risk Analysis of Preference Shares

Pay a higher yield than an equivalent bond but if the company fails to make enough profit the dividends can be suspended.

‘Preference’ refers to two types of preferential treatment which investors receive over ordinary shareholders:

The issuing company cannot pay a dividend to ordinary shareholders without first paying the preference share dividend.

Preference shares rank above ordinary shares when returning capital if a company is liquidated.

Because your income is fixed:

The preference share price will fluctuate with interest rates and inflation.

Over the years the dividend in real terms will be eroded by inflation, just as with all fixed income securities, which will severely cap

long-term returns.

Investing in preference shares provides investors with additional income, for the cost of forgoing the chance of equity-like gains.

Warrants

A warrant represents the right, but not the obligation, to purchase a share in a company at a specified time and price (the “exercise

price”). Sometimes the issuer will try to establish a market for the warrant and to register it with a listed exchange. In this case, the

price can be obtained from a stockbroker. But often, warrants are privately held or not registered, which makes their prices less

obvious.

Risk Analysis of Warrants

Prices are linked to the price of the underlying share, but are more volatile.

If the share price is less than the exercise price at the exercise date, the warrants are worthless.

Conversely, a profit is made if the share price climbs above the exercise price plus the price paid for the warrant itself.

Warrant prices magnify sentiment on underlying ordinary shares and fluctuate depending on supply and demand of both the

underlying shares and the warrants.


Equity Funds

Unit trusts, OEICs (Open Ended Investment Companies) and life funds, pool investors’ money and invest in a large portfolio of shares.

Units or shares are sold, each representing a small but equal fraction of a portfolio of typically 50 to 100 different holdings. Funds

enable you to access professional fund management, and offer the benefits of diversification on small investments (as low as £1000).

Unit Trusts and OEICs are similar but differ in the way their prices are calculated and in their legal status. Unit Trusts are established

as trusts and OEICs are incorporated as companies. Unit Trusts and OEICs can create or cancel units according to demand. The unit

or share price fluctuates daily to reflect the exact value of the investments held.

There are two main types of unit:

Income units where dividend income generated by the underlying holdings is distributed, and

Accumulation units where income is ‘rolled-up’ in the price of the unit.

Some funds offer both types of unit; others offer only one. Tracker funds aim to track a particular index, for example the FTSE 100.

Risk Analysis of Unit Trusts and OEICs

The volatility and the risk of each fund will depend on the type of investments held within it and also the fund manager’s strategy.

Investment Trusts

Investment trusts spread the risk of investing in the stock market across a portfolio of shares. They are incorporated as companies

and the shares are traded on the stock exchange. Investment trusts are “closed-ended”, with a finite number of shares in issue.

Risk Analysis of Investment Trusts

The share price of an investment trust is volatile as it is determined by the market. If an investment trust falls out of favour with the

market, its share price can fall so that it trades at a discount to the net asset value (“NAV”) of the underlying assets. Conversely a trust

which is in demand can trade at a premium to NAV. Unless a trust is liquidated, at which point the value of the assets will be

distributed, it is the share price rather than the NAV which determines how your investment performs, although the NAV will be one of

the factors that determines share price movement. A large discount to NAV signals a buying opportunity, but can also indicate

concerns about future performance.

An added risk is that investment trusts are permitted to borrow in order to invest, thereby “gearing” returns. Fund managers will use

gearing if they believe the market is going up in order to make extra profits with the borrowed money. If share prices fall they make a loss

on the shares and still have to pay off the debt.

Property

Commercial Property

Investors looking for tangible real assets often choose to invest in commercial property.

In the UK, commercial property is owned by investors (including pension funds and insurance companies; listed property companies,

Real Estate Investment Trusts (“REITs”) and private property companies; overseas investors; and private investors) and by owner

occupiers (mainly private companies and public bodies). Owner occupiers are gradually decreasing as owners of commercial property

as they seek to reduce the capital tied up in their buildings by selling them to investors and taking a leaseback.

Private investors usually get exposure to commercial property indirectly, through investing in institutionally managed funds and

through acquiring shares in listed property funds or REITs. Private investors are often unable to acquire commercial property directly

because of the relatively large amounts of capital required. However, Credo offers its clients the opportunity to acquire commercial

property by co-investing with its other clients and with joint-venture partners.



Risk Analysis of Commercial Property

Commercial property is attractive because:

It offers you the chance to receive stable and secure cash flows (generated from leases that provide a contracted rental income

stream and which usually require the tenant to keep the property in full repair and fully insured);

It should act as a hedge against inflation (because commercial property is a real asset, a significant part of the return from

commercial property comes as rental income and the leases often include upward-only rent reviews);

It offers diversification benefits when acquired as part of a balanced investment portfolio; and

Unlike with other asset classes there is an opportunity to enhance the property’s value through active management (e.g. by re-

negotiating the lease terms to either lengthen the lease or increase the rental income stream, or to refurbish the building and

potentially increase the rental income stream, or to redevelop the building for a different use and potentially improve the rental

income stream).

The main risks to consider include:

Liquidity Risk

Property can take some time to sell in normal market conditions, so commercial property is considered an illiquid investment. In a poor

market it will take even longer to find a buyer and it may not actually be possible to find a buyer at all at an acceptable price.

Valuation Risk

Unlike other financial assets, commercial property does not trade on an exchange with openly traded prices. The value of property is

generally a matter of a valuer’s opinion and value will also be affected by a range of factors. A downturn in the property market, a lack of

investor confidence, an oversupply of premises or a softening of demand will all be detrimental to the property’s value and are all factors

out of your control.

Location Risk

The location of a building is a key factor in determining its market value. However, the attractiveness of a location can change over time due to

a range of factors (as an example, the attractiveness of a retail store located in the best position on a high street may diminish if a major new

shopping centre is developed nearby).

Covenant Strength

A key factor which affects the value of a commercial building relates to the rental income that the property produces for its owner. The

tenant pays the rent and therefore the financial ability of the tenant to pay throughout the lease term is key. It is not just the risk of an

outright default that affects the value. If the credit strength (financial worth) of the tenant deteriorates during the period of ownership,

then that property’s value is also likely to be reduced.

Lease length

The length of the lease is also an important consideration because the tenant only pays the rent for the duration of the lease. If a

building is let to a good quality tenant for a long period then the rental income is assured, even if market conditions for property are

volatile. This is another of the features that makes commercial property attractive for investors.

So when acquiring a property, it is important to consider what the lease length will be when the property is likely to be resold. Many

leases include break options and it is market practice to assume that the lease will finish at the break point.

Debt

An investment in commercial property often exposes you to the extra risk of borrowing against the security of the property in order to

part finance the property acquisition (although this can also give you the potential for higher returns). If the debt is secured against a

single property or small portfolio of properties then the risk is concentrated. However, property investments funded through secured

debt facilities will run into serious difficulties if the tenant fails to pay the rent, if the value of the property falls, or if the borrower cannot

repay (or refinance) the debt when due since the borrower may then breach the borrowing terms (normally being the loan to value,

interest cover or repayment covenants).


General economy

National and local economic conditions affect the property market.

Changes in interest rates or the availability of mortgage funds may render the sale of properties difficult or unattractive. These could cause

fluctuations in occupancy rates, rent schedules or operating expenses, causing a negative effect on the value of property assets.

Like the economy, commercial property appears to go through cycles; periods of growth leading to oversupply and market weakness,

followed by stabilisation, absorption and then growth, leading to a shortage of supply.

The simplest measure of property value is ‘initial yield’ (current annual rental income divided by the purchase price of the property

including purchase costs). The average initial yield across the whole property market fluctuates over time and may reflect the general

economic cycle and/or specific changes in attitude towards property.

The level of interest rates in the economy affects the average initial yield; normally the lower the interest rates, then the lower the

average initial yields.

Any investor in property faces the risks of initial yields rising and therefore value decreasing, either because of a rise in interest rates

or for other reasons. In a recession, general risk criteria rise as do return requirements. So property yields could rise even when

interest rates do not.

Sector Risk

Every property is part of a particular business sector (the most important sectors for commercial property being Retail, Offices and

Industrial). Sectors can and do perform differently from the market as a whole and therefore the property’s value may be affected by

the performance of its particular sector.

Rental Growth

A financial asset can be valued as the discounted value of its future income stream; in property the income stream is its rental income.

The value of a property will reflect market expectations as to the growth of its rental income and changes in the expectations for rental

growth will have a profound impact on the value of the property.

If the expectation for a property investment is that rents will grow by a certain amount and that does not happen, then the returns from that

property will inevitably be lower than anticipated. Rental growth will be affected by many factors; the national economy, local trading

conditions, availability of alternative space etc.

Property Running Costs

Rates, taxes, utility costs, debt service, maintenance and refurbishment costs and insurance levies are all costs that must be met even

when the property is vacant. Thus, the cost of maintaining a property may exceed its rental income.

Product Risk

Usually commercial property is acquired through a vehicle or structure such as a company or limited partnership. Whilst these can help

spread the risk of investing, in some cases the structure itself may bring additional risks. Investing alongside other investors inevitably

means you are not in control of key decisions.

Regulatory Risk

Changes to the tax laws, planning regulations, building, environmental and other applicable laws, rent control laws or real property tax

rates all affect the value of property and are out of your control.

Development Risk

Property development brings specific risks and potential rewards and it requires additional skills. The risks include the project

management of costs, liability of suppliers, raising finance and managing cash flow and, above all, the risk of ensuring there is

appropriate demand for the finished property. Developments can last several years and any rewards are usually received at the end of

the project when the building is sold or rented out.



Alternative Investments

Non-Mainstream Pooled Investments (NMPIs)

Investors looking for diversification and access to different markets and securities at a lower cost than from making a direct investment

may be interested in NMPIs. These include, unregulated collective investment schemes, special purpose vehicles, hedge funds, and

property funds that are not authorised or regulated by the FCA.

There are, however, numerous risks associated with investing in NMPIs, which investors may not face investing in more traditional

asset classes.

Risk Analysis of NMPIs

Investing in NMPIs means that, where you would otherwise have been entitled to protections as a retail client, you may not have:

The right to compensation through the Financial Services Compensation Scheme in the event of a default.

Access to the Financial Ombudsman in the event of a dispute.

NMPIs may not be subject to the control and oversight of a regulator, and may be incorporated in a jurisdiction that doesn’t have

equivalence with the UK in terms of due diligence, auditing standards, and other such requirements.

The main NMPI risks to consider include:

Liquidity Risk

As there may not be a recognisable market for some of the investments within NMPIs, it may be difficult for NMPIs to trade such

investments, or to obtain reliable information about their value, or the extent of the risks to which such investments are exposed. This

may hinder the ability of an NMPI to value its shares or make redemptions for investors.

Currency Risk

NMPIs are often denominated in different currencies. Consequently, performance may be affected, unfavourably as well as favourably, by

fluctuations in foreign currency exchange rates.

Warrants and Derivatives Risk

Warrant prices magnify sentiment on underlying ordinary shares and fluctuate depending on supply and demand of both the

underlying shares and the warrants. Derivatives involve additional risks, some of which are outlined in the following section.

Property Risk

Property funds invest in property which may be difficult to sell and which may result in you not being able to redeem your investment

when you want to. Usually investments in these funds should be held for the long term. There is typically no regular market for these

investments and it may be difficult to sell at a reasonable price.

Private Equity Risk

Such investments are illiquid as there is no regular market for the investment. You will normally be committed to the investment until

the Private Equity fund manager resolves to sell the investment. Prior redemption may result in material loss.

Derivatives

A derivative is a security whose price depends on the value of one or more underlying assets. The security itself is merely a contract between

two or more parties. While these products can be useful in the management of investment risk, different instruments involve different levels of

exposure to numerous risks. In deciding whether to trade in such instruments, investors should be aware of the following:


Risk Analysis of Futures

A future is a type of derivative that obliges the party to make, or to take, delivery of the underlying asset of the contract at a future

date, or in some cases to settle the position in cash. They carry a high degree of risk:

The leverage (that is, borrowing to increase the potential return on an investment) often obtainable in futures trading means that a

small deposit can lead to large losses as well as gains.

It also means that a small movement in the underlying asset can generate large losses or gains in the value of the investment.

Deposited collateral for futures trading may lose its identity as your property once dealings on your behalf are undertaken. Even if

your dealings ultimately prove profitable, you may not get back the same assets which you deposited and may have to accept

payment in cash.

Risk Analysis of Options

An option is a derivative contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific

price on or before a certain date. It is a binding contract with strictly defined terms and properties. Like futures, they carry a high

degree of risk:

Buying options involves less risk than selling (known as “writing”) options because if the price of the underlying asset moves

against you, you can simply allow the option to lapse. Your maximum loss is limited to the premium, plus any commission or other

transaction charges.

Writing (i.e. selling) options involves considerably greater risk. Investors may be liable for margin to maintain a position, and a loss

may be sustained well in excess of the premium received. By writing an option, an investor makes a legal obligation to purchase or

sell the underlying asset if the option is exercised against them, regardless of how far the option has moved from the exercise price.

The main derivative risks to consider include:

Foreign Market Risk

Foreign markets will involve different risks from UK markets. In some cases, the risks will be greater. The potential for profit or loss

from transactions on foreign markets or in foreign denominated contracts will be affected by fluctuations in foreign exchange rates.

Contingent Liability Risks

Contingent liability investment transactions, which are margined, require investors to make a series of payments against the purchase

price, instead of paying the whole purchase price immediately. If an investor sustains a total loss of the margin deposited with the

Custodian to establish or maintain a position, they may be called upon to pay substantial additional margin at short notice to maintain

the position. If they fail to do so, the position may be liquidated at a loss and the investor will be responsible for the resulting deficit.

Suspension of Trading Risk

Under certain trading conditions, it may be difficult or impossible to liquidate a position. This may occur, for example, at times of rapid

price movement if the price rises or falls in one trading session to such an extent that under the rules of the relevant exchange, trading

is suspended or restricted. Placing a stop-loss order will not necessarily limit your losses to the intended amounts, since market

conditions may make it impossible to execute such an order at the stipulated price.



Credo’s Approach to Risk

Every investor is unique. It is only once we have a thorough understanding of your reasons for investing, your expectations,

circumstances and attitudes to risk that we are able to determine how to meet your needs. Different levels of return involve different

levels of risk. It is the balance between these two factors that determines the construction of your portfolio. All investments are subject

to some form of risk. These risks vary in degree and you as an investor will have different levels of concern about each risk. From

those focused on protecting their money, to those willing to incur short-term losses for higher returns over the longer term, our

portfolios cater for all objectives, save that we do not offer investments or model portfolios that would be suitable for clients who are

looking for “Capital Protection” only, i.e. investors who want a portfolio with similar characteristics to that of a cash account.

At Credo, we recognise that investment risk and potential returns go hand-in-hand. Against this background, it is our philosophy that

an appropriate level of risk needs to be embraced and managed as a prerequisite for growing the longer term value of your portfolio.

The greater the risk, the greater the potential return.

The lower the risk, the lower your return is likely to be.

Different categories of investments - Cash, Fixed Interest, Equities, Property and Alternative Investments - carry different

risk/potential return ratios.

Different instruments within each category also vary in their risk and potential for return.

Getting the risk/return balance right will be decided by how much volatility (defined as a statistical measure of the dispersion of returns

for a given security or market index) you are prepared to accept in your investment portfolio. We aim to help you understand your risk

“profile” and to show you how best to match your investments to your profile.

Credo’s approach to risk needs to be considered in the context of our investment philosophy which is based on the following tenets:

Wealth is preserved and created by following a relatively patient, buy-and-hold approach.

We believe in a value-based approach to investing, given that the price which is paid when investing is one of the very few things

in financial markets that you can actually control.

We follow an unconstrained, high conviction approach (i.e. we only invest in assets that we have a strong belief in) to investing

(based on extensive in-house research), balanced by sufficient diversification within portfolios.

Yield is an important consideration across all asset classes.

Transaction costs have the potential to erode investment returns quickly; because of this, we not only follow a low-turnover

approach, but we also take a considered approach to transaction size.

We focus on the longer term, and so do not tend to revise our views based on the daily news-flow in financial markets or macro-

economic forecasts.

At Credo we start by defining risk as the potential to lose your money; accordingly, our approach to investing can be described as a

relatively conservative one, focusing first and foremost on capital preservation.

In order to assess the risk you are prepared and able to take, you should consider some of the factors below:

1. How much can you afford to invest and what percentage is this of your net wealth?

2. Will you expect to have sources of income outside of your investments?

3. Do you require a specific amount of periodic income from your investments?

4. How long do you anticipate holding your investments for?

5. To what extent are you comfortable with losses in the value of your investments?

The risk profiles below may help you identify your favoured investment approach.

No risk

Preserving your capital is the most important factor when you consider your savings or the amount you wish to invest.

You understand the effects of inflation on your capital (and any interest received) and how this can reduce the real value of your

money over time.

Cautious

You prefer lower risk investments but are willing to accept small downside risk to your capital in order to achieve a higher potential

return than cash deposits. Your holdings may include investment grade bonds.


Moderate

You are prepared to assume a moderate amount of capital risk, but with a lower allocation to growth assets and a focus on minimising

potential downside. There may be limited exposure to higher yielding bonds and low risk equities.

Growth

A large focus of your portfolio is on potential growth of capital over the long term. The portfolio accepts short term volatility as a trade-

off for higher potential returns. A substantial proportion of your portfolio will be allocated to riskier assets. This can take various forms,

for example, a portion of the portfolio may be invested in a diversified basket of large capitalisation equities listed in developed

markets, with the rest of the portfolio allocated to a mixture of investments (some of which may in fact be higher risk, such as small

capitalisation and/or emerging market equities and others that are lower risk, such as investment grade bonds).

Adventurous

This is the most flexible profile, with the ability to take significant risk to increase the return-generating potential. The portfolio may be subject to

market exposure and substantial short term volatility. Given the flexibility, the portfolio may be invested across a basket of diversified small and

large capitalisation equities, in both developing and emerging markets. However, lower risk securities may also be included, such as high yield

or even investment grade bonds.

We hope this document has given you a good introduction into the main investment risks, the various asset classes and assessing

your own risk capacity. Below is a short summary of how we apply this to risk management.

Risk Management

A simplified guide to Credo’s risk management

1. Credo classifies the potential investments available to you into risk categories based on their sensitivity to the stock market.

2. We assess your capacity to take risk as well as your risk attitude using our proprietary tools.

3. We evaluate the types of investments available that might be suitable based on your risk profile.

4. We determine the right mix of investments to maximise your return potential for the risk you are willing and able to take.

5. We make adjustments to ensure there is sufficient variation within this mix so that your portfolio is not over exposed to any single

type of risk. Consistent with Modern Portfolio Theory (as explained below) we look for the right level of diversification to maximise

the potential return as per the level of risk.

6. We continue to fine tune your portfolio on an on-going basis depending on how your investments perform and how the risks develop.

Discretionary and Advisory Managed Clients

When we manage your Account, we will always consider the risk of the overall portfolio. This investment methodology is based on Modern

Portfolio Theory which supports the idea that your investment objectives are best achieved by combining different risk assets rather than

investing in one type of risk rated range of investments. We determine the risk of each security that may be included in your portfolio

using our own methodology which may differ from conventional assessments and/or the methodology used by other investment advisers.

Advisory Dealing Clients

If you request it, we will give you advice relating to your investment decisions on a transaction by transaction basis, but we will not

take into account the assets you already hold in your portfolio (with us or elsewhere) or any previous advice we have given you or

your own investment methodology, nor will we monitor the performance of your investments or your portfolio as a whole.

Existing clients: We hope that this risk education document will help you to better understand the basic features of the different

investment opportunities that Credo is able to offer to you. One of our Relationship Managers will be able to provide you with more

detailed information about any particular investment that you may be interested in. Please don’t hesitate to contact us at

[email protected] if you require any assistance.

Form W-8BEN-E(February 2014)

Department of the Treasury Internal Revenue Service

Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities)

For use by entities. Individuals must use Form W-8BEN. Section references are to the Internal Revenue Code. Information about Form W-8BEN-E and its separate instructions is at www.irs.gov/formw8bene.

Give this form to the withholding agent or payer. Do not send to the IRS.

OMB No. 1545-1621

Do NOT use this form for: Instead use Form:

• U.S. entity or U.S. citizen or resident . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . W-9

• A foreign individual . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . W-8BEN (Individual)

• A foreign individual or entity claiming that income is effectively connected with the conduct of trade or business within the U.S. (unless claiming treaty benefits). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . W-8ECI

• A foreign partnership, a foreign simple trust, or a foreign grantor trust (unless claiming treaty benefits) (see instructions for exceptions) . . W-8IMY

• A foreign government, international organization, foreign central bank of issue, foreign tax-exempt organization, foreign private foundation, or government of a U.S. possession claiming that income is effectively connected U.S. income or that is claiming the applicability of section(s) 115(2), 501(c), 892, 895, or 1443(b) (unless claiming treaty benefits) (see instructions) . . . . W-8ECI or W-8EXP

• Any person acting as an intermediary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . W-8IMY

Part I Identification of Beneficial Owner

1 Name of organization that is the beneficial owner 2 Country of incorporation or organization

3 Name of disregarded entity receiving the payment (if applicable)

4 Chapter 3 Status (entity type) (Must check one box only): Corporation Disregarded entity Partnership

Simple trust Grantor trust Complex trust Estate Government

Central Bank of Issue Tax-exempt organization Private foundation

If you entered disregarded entity, partnership, simple trust, or grantor trust above, is the entity a hybrid making a treaty claim? If "Yes" complete Part III. Yes No

5 Chapter 4 Status (FATCA status) (Must check one box only unless otherwise indicated). (See instructions for details and complete the certification below for the entity's applicable status).

Nonparticipating FFI (including a limited FFI or an FFI related to a Reporting IGA FFI other than a registered deemed-compliant FFI or participating FFI).

Participating FFI.

Reporting Model 1 FFI.


Registered deemed-compliant FFI (other than a reporting Model 1 FFI or sponsored FFI that has not obtained a GIIN).

Sponsored FFI that has not obtained a GIIN. Complete Part IV.

Certified deemed-compliant nonregistering local bank. Complete Part V.

Certified deemed-compliant FFI with only low-value accounts. Complete Part VI.

Certified deemed-compliant sponsored, closely held investment vehicle. Complete Part VII.

Certified deemed-compliant limited life debt investment entity. Complete Part VIII.

Certified deemed-compliant investment advisors and investment managers. Complete Part IX.

Owner-documented FFI. Complete Part X.

Restricted distributor. Complete Part XI.

Nonreporting IGA FFI (including an FFI treated as a registered deemed-compliant FFI under an applicable Model 2 IGA). Complete Part XII.

Foreign government, government of a U.S. possession, or foreign central bank of issue. Complete Part XIII.

International organization. Complete Part XIV.

Exempt retirement plans. Complete Part XV.

Entity wholly owned by exempt beneficial owners. Complete Part XVI.

Territory financial institution. Complete Part XVII.

Nonfinancial group entity. Complete Part XVIII.

Excepted nonfinancial start-up company. Complete Part XIX.

Excepted nonfinancial entity in liquidation or bankruptcy. Complete Part XX.

501(c) organization. Complete Part XXI.

Nonprofit organization. Complete Part XXII.

Publicly traded NFFE or NFFE affiliate of a publicly traded corporation. Complete Part XXIII.

Excepted territory NFFE. Complete Part XXIV.

Active NFFE. Complete Part XXV.

Passive NFFE. Complete Part XXVI.

Excepted inter-affiliate FFI. Complete Part XXVII.

Direct reporting NFFE.

Sponsored direct reporting NFFE. Complete Part XXVIII. 6 Permanent residence address (street, apt. or suite no., or rural route). Do not use a P.O. box or in-care-of address (other than a registered address).

City or town, state or province. Include postal code where appropriate. Country

7 Mailing address (if different from above)

City or town, state or province. Include postal code where appropriate. Country

8 U.S. taxpayer identification number (TIN), if required 9a GIIN b Foreign TIN 10 Reference number(s) (see instructions)

Note. Please complete remainder of the form including signing the form in Part XXIX. For Paperwork Reduction Act Notice, see separate instructions. Cat. No. 59689N Form W-8BEN-E (2-2014)

Form W-8BEN-E (2-2014) Page 2

Part II Disregarded Entity or Branch Receiving Payment. (Complete only if disregarded entity or branch of an FFI in a country other than the FFI's country of residence.)

11 Chapter 4 Status (FATCA status) of disregarded entity or branch receiving payment

Limited Branch.

Participating FFI.



U.S. Branch.

12 Address of disregarded entity or branch (street, apt. or suite no., or rural route). Do not use a P.O. box or in-care-of address (other than a registered address).

City or town, state or province. Include postal code where appropriate.

Country

13 GIIN (if any)

Part III Claim of Tax Treaty Benefits (if applicable). (For chapter 3 purposes only)14 I certify that (check all that apply):

a The beneficial owner is a resident of within the meaning of the income tax

treaty between the United States and that country. b The beneficial owner derives the item (or items) of income for which the treaty benefits are claimed, and, if applicable, meets the

requirements of the treaty provision dealing with limitation on benefits (see instructions).

c The beneficial owner is claiming treaty benefits for dividends received from a foreign corporation or interest from a U.S. trade or business of a foreign corporation and meets qualified resident status (see instructions).

15 Special rates and conditions (if applicable—see instructions): The beneficial owner is claiming the provisions of Article

of the treaty identified on line 14a above to claim a % rate of withholding on (specify type of income): .

Explain the reasons the beneficial owner meets the terms of the treaty article:

Part IV Sponsored FFI That Has Not Obtained a GIIN

16 Name of sponsoring entity:

17 Check whichever box applies.

I certify that the entity identified in Part I:

• Is an FFI solely because it is an investment entity;

• Is not a QI, WP, or WT; and

• Has agreed with the entity identified above (that is not a nonparticipating FFI) to act as the sponsoring entity for this entity. I certify that the entity identified in Part I:

• Is a controlled foreign corporation as defined in section 957(a);

• Is not a QI, WP, or WT;

• Is wholly owned, directly or indirectly, by the U.S. financial institution identified above that agrees to act as the sponsoring entity for this entity; and

• Shares a common electronic account system with the sponsoring entity (identified above) that enables the sponsoring entity to identify all account holders and payees of the entity and to access all account and customer information maintained by the entity including, but not limited to, customer identification information, customer documentation, account balance, and all payments made to account holders or payees.

Part V Certified Deemed-Compliant Nonregistering Local Bank

18 I certify that the FFI identified in Part I:

• Operates and is licensed solely as a bank or credit union (or similar cooperative credit organization operated without profit) in its country of incorporation or organization;

• Engages primarily in the business of receiving deposits from and making loans to, with respect to a bank, retail customers unrelated to such bank and, with respect to a credit union or similar cooperative credit organization, members, provided that no member has a greater than five percent interest in such credit union or cooperative credit organization;

• Does not solicit account holders outside its country of organization;

• Has no fixed place of business outside such country (for this purpose, a fixed place of business does not include a location that is not advertised to the public and from which the FFI performs solely administrative support functions);

• Has no more than $175 million in assets on its balance sheet and, if it is a member of an expanded affiliated group, the group has no more than $500 million in total assets on its consolidated or combined balance sheets; and

• Does not have any member of its expanded affiliated group that is a foreign financial institution, other than a foreign financial institution that is incorporated or organized in the same country as the FFI identified in Part I and that meets the requirements set forth in this Part V.

Form W-8BEN-E (2-2014)


Part VI Certified Deemed-Compliant FFI with Only Low-Value Accounts

19 I certify that the FFI identified in Part I:

• Is not engaged primarily in the business of investing, reinvesting, or trading in securities, partnership interests, commodities, notional principal contracts, insurance or annuity contracts, or any interest (including a futures or forward contract or option) in such security, partnership interest, commodity, notional principal contract, insurance contract or annuity contract;

• No financial account maintained by the FFI or any member of its expanded affiliated group, if any, has a balance or value in excess of $50,000 (as determined after applying applicable account aggregation rules); and

• Neither the FFI nor the entire expanded affiliated group, if any, of the FFI, have more than $50 million in assets on its consolidated or combined balance sheet as of the end of its most recent accounting year.

Part VII Certified Deemed-Compliant Sponsored, Closely Held Investment Vehicle


21 I certify that the entity identified in Part I:

• Is an FFI solely because it is an investment entity described in §1.1471-5(e)(4);

• Is not a QI, WP, or WT;

• Has a contractual relationship with the above identified sponsoring entity that agrees to fulfill all due diligence, withholding, and reporting responsibilities of a participating FFI on behalf of this entity; and

• Twenty or fewer individuals own all of the debt and equity interests in the entity (disregarding debt interests owned by U.S. financial institutions, participating FFIs, registered deemed-compliant FFIs, and certified deemed-compliant FFIs and equity interests owned by an entity if that entity owns 100 percent of the equity interests in the FFI and is itself a sponsored FFI).

Part VIII Certified Deemed-Compliant Limited Life Debt Investment Entity


• Was in existence as of January 17, 2013; • Issued all classes of its debt or equity interests to investors on or before January 17, 2013, pursuant to a trust indenture or similar agreement; and • Is certified deemed-compliant because it satisfies the requirements to be treated as a limited life debt investment entity (such as the restrictions with respect to its assets and other requirements under § 1.1471-5(f)(2)(iv)).

Part IX Certified Deemed-Compliant Investment Advisors and Investment Managers


• Is a financial institution solely because it is an investment entity described in §1.1471-5(e)(4)(i)(A); and

• Does not maintain financial accounts.Part X Owner-Documented FFI

Note. This status only applies if the U.S. financial institution or participating FFI to which this form is given has agreed that it will treat the FFI as an owner-documented FFI (see instructions for eligibility requirements). In addition, the FFI must make the certifications below.

24a (All owner-documented FFIs check here) I certify that the FFI identified in Part I:

• Does not act as an intermediary;

• Does not accept deposits in the ordinary course of a banking or similar business;

• Does not hold, as a substantial portion of its business, financial assets for the account of others;

• Is not an insurance company (or the holding company of an insurance company) that issues or is obligated to make payments with respect to a financial account;

• Is not owned by or in an expanded affiliated group with an entity that accepts deposits in the ordinary course of a banking or similar business, holds, as a substantial portion of its business, financial assets for the account of others, or is an insurance company (or the holding company of an insurance company) that issues or is obligated to make payments with respect to a financial account; and

• Does not maintain a financial account for any nonparticipating FFI.



Part X Owner-Documented FFI (continued)Check box 24b or 24c, whichever applies.

b I certify that the FFI identified in Part I:

• Has provided, or will provide, an FFI owner reporting statement that contains:

• The name, address, TIN (if any), chapter 4 status, and type of documentation provided (if required) of every individual and specified U.S. person that owns a direct or indirect equity interest in the owner-documented FFI (looking through all entities other than specified U.S. persons);

• The name, address, TIN (if any), chapter 4 status, and type of documentation provided (if required) of every individual and specified U.S. person that owns a debt interest in the owner-documented FFI (including any indirect debt interest, which includes debt interests in any entity that directly or indirectly owns the payee or any direct or indirect equity interest in a debt holder of the payee) that constitutes a financial account in excess of $50,000 (disregarding all such debt interests owned by participating FFIs, registered deemed-compliant FFIs, certified deemed-compliant FFIs, excepted NFFEs, exempt beneficial owners, or U.S. persons other than specified U.S. persons); and

• Any additional information the withholding agent requests in order to fulfill its obligations with respect to the entity.

c I certify that the FFI identified in Part I has provided, or will provide, an auditor's letter, signed within four years of the date of payment,

from an independent accounting firm or legal representative with a location in the United States stating that the firm or representative has reviewed the FFI's documentation with respect to all of its owners and debt holders identified in §1.1471-3(d)(6)(iv)(A)(2), and that the FFI meets all the requirements to be an owner-documented FFI. The FFI identified in Part I has also provided, or will provide, an FFI owner reporting statement of its owners that are specified U.S. persons and Form(s) W-9, with applicable waivers.

Check box 24d if applicable.

d I certify that the entity identified in line 1 is a trust that does not have any contingent beneficiaries or designated classes with unidentified beneficiaries.

Part XI Restricted Distributor 25a (All restricted distributors check here) I certify that the entity identified in Part I:

• Operates as a distributor with respect to debt or equity interests of the restricted fund with respect to which this form is furnished;

• Provides investment services to at least 30 customers unrelated to each other and less than half of its customers are related to each other;

• Is required to perform AML due diligence procedures under the anti-money laundering laws of its country of organization (which is an FATF-compliant jurisdiction);

• Operates solely in its country of incorporation or organization, has no fixed place of business outside of that country, and has the same country of incorporation or organization as all members of its affiliated group, if any;

• Does not solicit customers outside its country of incorporation or organization;

• Has no more than $175 million in total assets under management and no more than $7 million in gross revenue on its income statement for the most recent accounting year;

• Is not a member of an expanded affiliated group that has more than $500 million in total assets under management or more than $20 million in gross revenue for its most recent accounting year on a combined or consolidated income statement; and

• Does not distribute any debt or securities of the restricted fund to specified U.S. persons, passive NFFEs with one or more substantial U.S. owners, or nonparticipating FFIs.

Check box 25b or 25c, whichever applies.

I further certify that with respect to all sales of debt or equity interests in the restricted fund with respect to which this form is furnished that are made after December 31, 2011, the entity identified in Part I:

b Has been bound by a distribution agreement that contained a general prohibition on the sale of debt or securities to U.S. entities and U.S. resident individuals and is currently bound by a distribution agreement that contains a prohibition of the sale of debt or securities to any specified U.S. person, passive NFFE with one or more substantial U.S. owners, or nonparticipating FFI.

c Is currently bound by a distribution agreement that contains a prohibition on the sale of debt or securities to any specified U.S. person, passive NFFE with one or more substantial U.S. owners, or nonparticipating FFI and, for all sales made prior to the time that such a restriction was included in its distribution agreement, has reviewed all accounts related to such sales in accordance with the procedures identified in §1.1471-4(c) applicable to preexisting accounts and has redeemed or retired any, or caused the restricted fund to transfer the securities to a distributor that is a participating FFI or reporting Model 1 FFI securities which were sold to specified U.S. persons, passive NFFEs with one or more substantial U.S. owners, or nonparticipating FFIs.

Part XII Nonreporting IGA FFI


• Meets the requirements to be considered a nonreporting financial institution pursuant to an applicable IGA between the United States and ;

• Is treated as a under the provisions of the applicable IGA (see instructions); and

• If you are an FFI treated as a registered deemed-compliant FFI under an applicable Model 2 IGA, provide your GIIN:Form W-8BEN-E (2-2014)


Part XIII Foreign Government, Government of a U.S. Possession, or Foreign Central Bank of Issue

27 I certify that the entity identified in Part I is the beneficial owner of the payment and is not engaged in commercial financial activities of a type engaged in by an insurance company, custodial institution, or depository institution with respect to the payments, accounts, or obligations for which this form is submitted (except as permitted in §1.1471-6(h)(2)).

Part XIV International Organization

Check box 28a or 28b, whichever applies.

28a I certify that the entity identified in Part I is an international organization described in section 7701(a)(18).

b I certify that the entity identified in Part I:

• Is comprised primarily of foreign governments; • Is recognized as an intergovernmental or supranational organization under a foreign law similar to the International Organizations Immunities Act;

• The benefit of the entity's income does not inure to any private person;

• Is the beneficial owner of the payment and is not engaged in commercial financial activities of a type engaged in by an insurance company, custodial institution, or depository institution with respect to the payments, accounts, or obligations for which this form is submitted (except as permitted in §1.1471-6(h)(2)).

Part XV Exempt Retirement Plans

Check box 29a, b, c, d, e, or f, whichever applies.

29a I certify that the entity identified in Part I:

• Is established in a country with which the United States has an income tax treaty in force (see Part III if claiming treaty benefits);

• Is operated principally to administer or provide pension or retirement benefits; and

• Is entitled to treaty benefits on income that the fund derives from U.S. sources (or would be entitled to benefits if it derived any such income) as a resident of the other country which satisfies any applicable limitation on benefits requirement.

b I certify that the entity identified in Part I:

• Is organized for the provision of retirement, disability, or death benefits (or any combination thereof) to beneficiaries that are former employees of one or more employers in consideration for services rendered;

• No single beneficiary has a right to more than 5% of the FFI's assets;

• Is subject to government regulation and provides annual information reporting about its beneficiaries to the relevant tax authorities in the country in which the fund is established or operated; and

• Is generally exempt from tax on investment income under the laws of the country in which it is established or operates due to its status as a retirement or pension plan;

• Receives at least 50% of its total contributions from sponsoring employers (disregarding transfers of assets from other plans described in this part, retirement and pension accounts described in an applicable Model 1 or Model 2 IGA, other retirement funds described in an applicable Model 1 or Model 2 IGA, or accounts described in §1.1471-5(b)(2)(i)(A));

• Either does not permit or penalizes distributions or withdrawals made before the occurrence of specified events related to retirement, disability, or death (except rollover distributions to accounts described in §1.1471-5(b)(2)(i)(A) (referring to retirement and pension accounts), to retirement and pension accounts described in an applicable Model 1 or Model 2 IGA, or to other retirement funds described in this part or in an applicable Model 1 or Model 2 IGA); or

• Limits contributions by employees to the fund by reference to earned income of the employee or may not exceed $50,000 annually.

c I certify that the entity identified in Part I:

• Is organized for the provision of retirement, disability, or death benefits (or any combination thereof) to beneficiaries that are former employees of one or more employers in consideration for services rendered;

• Has fewer than 50 participants;

• Is sponsored by one or more employers each of which is not an investment entity or passive NFFE;

• Employee and employer contributions to the fund (disregarding transfers of assets from other plans described in this part, retirement and pension accounts described in an applicable Model 1 or Model 2 IGA, or accounts described in §1.1471-5(b)(2)(i)(A)) are limited by reference to earned income and compensation of the employee, respectively;

• Participants that are not residents of the country in which the fund is established or operated are not entitled to more than 20 percent of the fund's assets; and

• Is subject to government regulation and provides annual information reporting about its beneficiaries to the relevant tax authorities in the country in which the fund is established or operates.

d I certify that the entity identified in Part I is formed pursuant to a pension plan that would meet the requirements of section 401(a), other

than the requirement that the plan be funded by a trust created or organized in the United States.

e I certify that the entity identified in Part I is established exclusively to earn income for the benefit of one or more retirement funds

described in this part or in an applicable Model 1 or Model 2 IGA, accounts described in §1.1471-5(b)(2)(i)(A) (referring to retirement and pension accounts), or retirement and pension accounts described in an applicable Model 1 or Model 2 IGA.



Part XV Exempt Retirement Plans (Continued)f I certify that the entity identified in Part I:

• Is established and sponsored by a foreign government, international organization, central bank of issue, or government of a U.S. possession (each as defined in §1.1471-6) or an exempt beneficial owner described in an applicable Model 1 or Model 2 IGA to provide retirement, disability, or death benefits to beneficiaries or participants that are current or former employees of the sponsor (or persons designated by such employees); or

• Is established and sponsored by a foreign government, international organization, central bank of issue, or government of a U.S. possession (each as defined in §1.1471-6) or an exempt beneficial owner described in an applicable Model 1 or Model 2 IGA to provide retirement, disability, or death benefits to beneficiaries or participants that are not current or former employees of such sponsor, but are in consideration of personal services performed for the sponsor.

Part XVI Entity Wholly Owned by Exempt Beneficial Owners


• Is an FFI solely because it is an investment entity;

• Each direct holder of an equity interest in the investment entity is an exempt beneficial owner described in §1.1471-6 or in an applicable Model 1 or Model 2 IGA; • Each direct holder of a debt interest in the investment entity is either a depository institution (with respect to a loan made to such entity) or an exempt beneficial owner described in §1.1471-6 or an applicable Model 1 or Model 2 IGA. • Has provided an owner reporting statement that contains the name, address, TIN (if any), chapter 4 status, and a description of the type of documentation provided to the withholding agent for every person that owns a debt interest constituting a financial account or direct equity interest in the entity; and

• Has provided documentation establishing that every owner of the entity is an entity described in §1.1471-6(b), (c), (d), (e), (f) and/or (g) without regard to whether such owners are beneficial owners.

Part XVII Territory Financial Institution 31 I certify that the entity identified in Part I is a financial institution (other than an investment entity) that is incorporated or organized under

the laws of a possession of the United States.

Part XVIII Excepted Nonfinancial Group Entity


• Is a holding company, treasury center, or captive finance company and substantially all of the entity's activities are functions described in §1.1471-5(e)(5)(i)(C) through (E);

• Is a member of a nonfinancial group described in §1.1471-5(e)(5)(i)(B);

• Is not a depository or custodial institution (other than for members of the entity's expanded affiliated group); and • Does not function (or hold itself out) as an investment fund, such as a private equity fund, venture capital fund, leveraged buyout fund, or any investment vehicle with an investment strategy to acquire or fund companies and then hold interests in those companies as capital assets for investment purposes.

Part XIX Excepted Nonfinancial Start-Up Company

33 I certify that the entity identified in Part I:• Was formed on (or, in the case of a new line of business, the date of board resolution approving the new line of business)

(date must be less than 24 months prior to date of payment);

• Is not yet operating a business and has no prior operating history or is investing capital in assets with the intent to operate a new line of business other than that of a financial institution or passive NFFE;

• Is investing capital into assets with the intent to operate a business other than that of a financial institution; and

• Does not function (or hold itself out) as an investment fund, such as a private equity fund, venture capital fund, leveraged buyout fund, or any investment vehicle whose purpose is to acquire or fund companies and then hold interests in those companies as capital assets for investment purposes.

Part XX Excepted Nonfinancial Entity in Liquidation or Bankruptcy

34 I certify that the entity identified in Part I:• Filed a plan of liquidation, filed a plan of reorganization, or filed for bankruptcy on ;

• During the past 5 years has not been engaged in business as a financial institution or acted as a passive NFFE;

• Is either liquidating or emerging from a reorganization or bankruptcy with the intent to continue or recommence operations as a nonfinancial entity; and

• Has, or will provide, documentary evidence such as a bankruptcy filing or other public documentation that supports its claim if it remains in bankruptcy or liquidation for more than three years.

Part XXI 501(c) Organization

35 I certify that the entity identified in Part I is a 501(c) organization that:

• Has been issued a determination letter from the IRS that is currently in effect concluding that the payee is a section 501(c) organization that is dated ; or

• Has provided a copy of an opinion from U.S. counsel certifying that the payee is a section 501(c) organization (without regard to whether the payee is a foreign private foundation).



Part XXII Non-Profit Organization

36 I certify that the entity identified in Part I is a non-profit organization that meets the following requirements:

• The entity is established and maintained in its country of residence exclusively for religious, charitable, scientific, artistic, cultural or educational purposes;

• The entity is exempt from income tax in its country of residence;

• The entity has no shareholders or members who have a proprietary or beneficial interest in its income or assets; • Neither the applicable laws of the entity's country of residence nor the entity's formation documents permit any income or assets of the entity to be distributed to, or applied for the benefit of, a private person or non-charitable entity other than pursuant to the conduct of the entity's charitable activities or as payment of reasonable compensation for services rendered or payment representing the fair market value of property which the entity has purchased; and

• The applicable laws of the entity's country of residence or the entity's formation documents require that, upon the entity's liquidation or dissolution, all of its assets be distributed to an entity that is a foreign government, an integral part of a foreign government, a controlled entity of a foreign government, or another organization that is described in this Part XXII or escheats to the government of the entity's country of residence or any political subdivision thereof.

Part XXIII Publicly Traded NFFE or NFFE Affiliate of a Publicly Traded Corporation Check box 37a or 37b, whichever applies.

37a I certify that:

• The entity identified in Part I is a foreign corporation that is not a financial institution; and

• The stock of such corporation is regularly traded on one or more established securities markets, including (name one securities exchange upon which the stock is regularly traded).

b I certify that:

• The entity identified in Part I is a foreign corporation that is not a financial institution;

• The entity identified in Part I is a member of the same expanded affiliated group as an entity the stock of which is regularly traded on an established securities market;

• The name of the entity, the stock of which is regularly traded on an established securities market, is ; and

• The name of the securities market on which the stock is regularly traded is .

Part XXIV Excepted Territory NFFE 38 I certify that:

• The entity identified in Part I is an entity that is organized in a possession of the United States;

• The entity identified in Part I:

• Does not accept deposits in the ordinary course of a banking or similar business,

• Does not hold, as a substantial portion of its business, financial assets for the account of others, or

• Is not an insurance company (or the holding company of an insurance company) that issues or is obligated to make payments with respect to a financial account; and

• All of the owners of the entity identified in Part I are bona fide residents of the possession in which the NFFE is organized or incorporated.

Part XXV Active NFFE 39 I certify that:

• The entity identified in Part I is a foreign entity that is not a financial institution;

• Less than 50% of such entity's gross income for the preceding calendar year is passive income; and

• Less than 50% of the assets held by such entity are assets that produce or are held for the production of passive income (calculated as a weighted average of the percentage of passive assets measured quarterly) (see instructions for the definition of passive income).

Part XXVI Passive NFFE 40a I certify that the entity identified in Part I is a foreign entity that is not a financial institution (other than an investment entity organized in a

possession of the United States) and is not certifying its status as a publicly traded NFFE (or affiliate), excepted territory NFFE, active NFFE, direct reporting NFFE, or sponsored direct reporting NFFE.

Check box 40b or 40c, whichever applies.

b I further certify that the entity identified in Part I has no substantial U.S. owners, or

c I further certify that the entity identified in Part I has provided the name, address, and TIN of each substantial U.S. owner of the NFFE in Part XXX.Part XXVII Excepted Inter-Affiliate FFI


• Is a member of an expanded affiliated group;

• Does not maintain financial accounts (other than accounts maintained for members of its expanded affiliated group);• Does not make withholdable payments to any person other than to members of its expanded affiliated group that are not limited FFIs or limited branches;

• Does not hold an account (other than a depository account in the country in which the entity is operating to pay for expenses) with or receive payments from any withholding agent other than a member of its expanded affiliated group; and

• Has not agreed to report under §1.1471-4(d)(2)(ii)(C) or otherwise act as an agent for chapter 4 purposes on behalf of any financial institution, including a member of its expanded affiliated group.



Part XXVIII Sponsored Direct Reporting NFFE


43 I certify that the entity identified in Part I is a direct reporting NFFE that is sponsored by the entity identified in line 42.

Part XXIX Certification

Under penalties of perjury, I declare that I have examined the information on this form and to the best of my knowledge and belief it is true, correct, and complete. I further certify under penalties of perjury that:

• The entity identified on line 1 of this form is the beneficial owner of all the income to which this form relates, is using this form to certify its status for chapter 4

purposes, or is a merchant submitting this form for purposes of section 6050W,

• The entity identified on line 1 of this form is not a U.S. person,• The income to which this form relates is: (a) not effectively connected with the conduct of a trade or business in the United States, (b) effectively connected but is

not subject to tax under an income tax treaty, or (c) the partner’s share of a partnership's effectively connected income, and

• For broker transactions or barter exchanges, the beneficial owner is an exempt foreign person as defined in the instructions.

Furthermore, I authorize this form to be provided to any withholding agent that has control, receipt, or custody of the income of which the entity on line 1 is the beneficial owner or any withholding agent that can disburse or make payments of the income of which the entity on line 1 is the beneficial owner.

I agree that I will submit a new form within 30 days if any certification on this form becomes incorrect.

Sign Here

Signature of individual authorized to sign for beneficial owner Print Name Date (MM-DD-YYYY)

I certify that I have the capacity to sign for the entity identified on line 1 of this form.

Part XXX Substantial U.S. Owners of Passive NFFE

As required by Part XXVI, provide the name, address, and TIN of each substantial U.S. owner of the NFFE. Please see instructions for definition of substantial U.S. owner.

Name Address TIN
