BROKER SELECTION AND ASSESSMENT POLICY

BROKER SELECTION AND ASSESSMENT POLICY Date created: 1 Nvember 2007 Last updated: 19 Nvember 2012 Departments affected: Management departments, senir management, CICD Subject: Definitin f brker selectin and assessment prcesses, selectin f new rder placement methds Persns in charge: Managers, Managing Directrs, Head f Middle Office, Cmpliance and Internal Cntrl Officer, DIS INTRODUCTION The Eurpean Directive n markets in financial instruments (MiFID) came int effect n 1 Nvember 2007. It is mainly cncerned with btaining the best pssible result and best serving client interests while prmting market integrity. The Directive asks service prviders t take all reasnable measures t btain the best pssible result when executing rders placed n behalf f their clients. OBJECTIVE Pursuant t Article L. 533-18 f the French Mnetary and Financial Cde transpsing Article 21 f Directive n. 2004/39/EC - Markets in Financial Instruments (MiFID) and Articles 314-75 and 314-75-1 f the AMF (Autrité des marchés financiers/french Financial Markets Authrity) General Regulatin, Tcqueville Finance, as an asset management cmpany, has an bligatin t act in the best interests f its clients. Due t its status as an asset management cmpany, Tcqueville Finance is nt a market member but transmits rders n behalf f the UCITS it manages and the accunts it manages under mandate t authrised market intermediaries. The Best Executin principle takes the frm f Best Selectin, which invlves selecting, fr each class f instruments, the entities t which rders are transmitted fr executin. Best Selectin requires that all reasnable steps be taken t btain, in the majrity f pssible cases, the best executin pssible fr rders transmitted n behalf f the prtflis the management cmpany manages. Additinally, t better meet MiFID's requirements, Tcqueville Finance has elected t transmit its transactins thrugh an utsurced trading desk, the Exé cmpany. Since 19 Nvember 2012, this intermediary has handled transmissin f all rders t the market members selected in cmpliance with the new regulatin. This intermediary's equity market expertise, cmbined with Tcqueville Finance's management 1

capabilities, ensures cmpliance with the regulatin's requirement t btain the best pssible result. This dcument is subject t change at any time withut ntice. It is available n the Tcqueville Finance website at www.tcquevillefinance.fr REGULATORY FRAMEWORK Articles 314-69 and 314-75 et. seq. f the AMF General Regulatin Article 533-18 f the French Mnetary and Financial Cde SCOPE Management cmpany classificatin Tcqueville Finance has chsen t cnsider itself a prfessinal client and asks brkers t classify it as such; this impses a best executin bligatin n them vis-à-vis ur cmpany. Criteria fr selecting the best financial intermediaries fr equity rder executin Tcqueville Finance uses three criteria in its Best Selectin prcedure t select and assess the best executin intermediaries with the ultimate aim f achieving best executin. These criteria are based, first, n a qualitative analysis; secnd, n a quantitative analysis; and, lastly, n a middle ffice technical rating. - 1st criterin: Qualitative aspects Access t executin venues allwing fr best executin n a regular basis, Cnnectivity, Market technlgy, Direct market access, Sales trading infrmatin, Disclsure f lists f interests, Access t facilitatin and t market makers' prices, Quality f Middle and Back Office supprt. - 2nd criterin: Quantitative aspect: measuring executin perfrmance - TCA. One measurement f executin perfrmance (Trading Cst Analysis) is perfrmed. This enables Tcqueville Finance t cmpare the quality f the executins carried ut by different intermediaries ver the same vting perid. The measurement aggregates the number f basis pints destryed r created at each executin during the perid under review, fr each intermediary. - 3rd criterin: Middle Office rating The middle ffice rating is based n the rderly settlement f transactins. This rating changes based n the quality f the cnfirmatins and settlements and n the quantity f fails and fails management. Legal precnditins fr apprving a new brker: - signature f an agreement with Tcqueville Finance; - signature f an rder transmissin-receptin agreement between the brker and Exé; - MiFID classificatin f the management cmpany as a prfessinal client ; - review f the brker's best executin plicy; - cnfiguratin f IT tls by the middle ffice and Exé; - authrisatin frm the Cmpliance and Internal Cntrl Officer. 2

By nature, new brkers cannt be subject t a quantitative and qualitative review, r t a middle ffice rating. New brkers are selected n the basis f their reputatin, their technical and human resurces, and their ability t prvide best executin in view f their best executin plicy, based n technical and technlgical criteria: access t different markets, FIX cnnectivity, etc. Prcedures fr and frequency f market brker selectin Brker Review Rle f the Brker Cmmittee Every six mnths, the management cmpany reviews the brkers selected in the previus six mnths based n the three criteria listed abve and decides which new brkers will be added t the list f brkers selected fr the next six mnths. The Brker Cmmittee is therefre respnsible fr: selecting new brkers; rating brkers based n the three criteria listed abve. Cmpsitin f the Brker Cmmittee: several members f the management team; ne r mre members f management; the head f Middle Office; the Cmpliance and Internal Cntrl Officer; ne r mre members f the Exé cmpany. The Brker Cmmittee is respnsible fr reviewing brkers based n the three criteria cited abve. It is tasked with deciding whether t maintain r remve each f the brkers n the list f brkers that will be selected and retained fr the next six mnths based n the "best selectin" prcess. Best Ranking The list f brkers established upn cmpletin f the best selectin prcess is then classified and ranked based n qualitative criteria as evaluated by the management team: research quality, crprate access, ability t handle IPOs, etc. This rating is described in the Best Ranking prcedure. It is used t establish a brker ranking that determines the vlume f brkerage t be allcated t each brker in the next six mnths. Methdlgy fr selecting the dealer respnsible fr executing an rder (equity rders) Once an rder has been transmitted t Exé, fr each rder given (that is, taken individually), Exé selects a brker frm the list f intermediaries established under this plicy based n the fllwing criteria: Likelihd f executin and settlement Characteristics f the rder: depending n the size and nature f the rder, Exé will endeavur t limit the market impact and the estimated pprtunity cst by relying n the experience f its traders and n the market infrmatin available at the time f the 3

rder transmissin. It will use its discretin in the fllwing areas in particular: liquidity: expressin f interest t detect an ppsite flw n this rder (blck r facilitatin); executin venues t which the dealer is cnnected and that allw fr best executin, in terms f price, cst and executin speed; direct access t the market n which the instrument is listed; rderly executin f the same stck in previus transactins; cmpliance with allcatins fr the perid; fundamental mnitring f the stck. Exé will nt be required t cmply with this methdlgy: When it receives an instructin regarding the chice f dealer (directed rder): in that case, Exé respects ur chice f client and is released frm the best selectin bligatin. The dealer is respnsible fr best executin. Tcqueville Finance is therefre respnsible fr best selectin. When it receives ne r mre instructins regarding the executin methd (specific instructin(s)): Exé and the dealer transmit and execute the rder in accrdance with this (these) instructin(s) and are released frm the best executin bligatin fr this (these) instructin(s). In that case, the best executin respnsibility lies with Tcqueville Finance with respect t this (these) specific instructin(s). Executin venue: Depending n the rder executin plicy adpted by each intermediary r cunterparty selected, and in cmpliance with their best executin bligatin, rders may be executed: n regulated markets; n regularly perating rganised markets (e.g., Free Market, Alternext); n multilateral trading facilities; with systematic internalisers. Tcqueville Finance reserves the right t use ther executin venues where apprpriate in the cntext f this executin plicy. CONTROL, REVIEW AND MODIFICATION OF THE BEST EXECUTION, BEST SELECTION POLICY At least nce a year, Tcqueville Finance assesses the effectiveness f the selectin and executin prcedures described and f this plicy s as t identify any deficiencies and crrect them, as applicable, r t imprve it. Annual review Tcqueville Finance cnducts an annual review f the rewrked executin plicy and the rder transmissin and executin prcedures. Peridic updates Whenever a meaningful change is made that affects Tcqueville Finance's ability t cntinue t btain best transmissin n a regular basis with a view t best rder executin, Tcqueville Finance als reviews its executin plicy. At least nce a year the selectin cmmittee reviews the dealers' markets, techniques and qualities t verify their ability t btain the best pssible result n a regular basis. This assessment is nt cnducted n an rder-by-rder basis but as a whle. 4

Infrmatinal resurces available t clients regarding the executin plicy Tcqueville Finance ntifies clients f any significant changes in its executin plicy n the fllwing media: Cmpany website: www.tcquevillefinance.fr This dcument may be sent by mail r email upn request. Change in executin plicy: Any new versin will be made available t clients n the website www.tcquevillefinance.fr r sent by mail r email upn request. The best ranking research rating The selectin prcess is defined as fllws at Tcqueville Finance, and was develped by the cmmittee cmpsed f: several members f the management team; ne r mre members f management; the Cmpliance and Internal Cntrl Officer. Frequency The vting prcess is carried ut every six mnths. Criteria and vters The fllwing divisins take part in rating the research based n the fllwing criteria: Cllective managers and discretinary managers: Research quality, quality f advice and sales cverage, frequency and quality f meetings with issuers; Management departments: assessment f creditwrthiness, and reputatin. Changes t weightings The verall rating f rated service prviders may be affected by a weighting that depends n the actual cverage achieved by each intermediary with the managers. Vting: Vtes are cast every six mnths, in the frm f a web interview. Each interview is cnducted under the authrity f the Cmpliance and Internal Cntrl Officer wh keeps a recrd f the individual ratings and the aggregate scre/rank. 5