Order Execution Policy

This policy has been documented to explain how Thesis ensures that it takes all reasonable steps to obtain, when executing orders for clients, the best possible result for them while taking account of the execution factors listed below.

1. Thesis Asset Management plc (“The firm") does not itself execute client orders, but for discretionary and non-discretionary clients will transmit all orders to one of a number of UK brokers
2. As at February 2010, the brokers used were A J Bell Securities Limited, Winterflood Securities, Barclays Stockbrokers, Oriel Securities Limited, Cenkos Securities, Arbuthnot Securities Limited, Collins Stewart Europe Limited, HSBC, Numis Securities Limited and ODL Securities Limited
3. The execution factors taken into account when deciding to use a particular broker are price, costs, speed, size of trade, likelihood of execution and settlement and stock liquidity
4. The firm executes orders, through its brokers, on the London Stock Exchange and any other recognised exchange required for the trade
5. All transactions on collective investment schemes are executed directly with the manager/authorised corporate director of the scheme in question. Orders are often placed through the electronic messaging system known as EMX
6. Orders for fixed interest securities are executed by A J Bell Securities Limited and Winterflood Securities
7. Derivatives may be dealt by Directors or the Head of Dealing only. Currently they are traded through Calyon Financial
8. The quality of service that the firm receives from its brokers is monitored by the Thesis head dealer who reports to the Thesis Operations Director
9. Any specific instructions from a client may prevent the firm from taking the steps that it has designed and implemented in its execution policy to obtain the best possible result for the execution of those orders in respect of the elements covered by those instructions.

This policy is updated annually.

Updated February 2010