Pillar III Disclosure

The Capital Requirements Directive sets out the disclosure requirements for operating risks under Pillar 3 to complement the minimum capital requirements under Pillar 1 and the supervisory review process under Pillar 2. The aim of Pillar 3 is to promote market discipline by allowing market participants to access information on risk exposures and risk management policies adopted by the Company. The regulations for the disclosures required under Pillar 3 are set out in Annex XII of the Directive 2006.48 / European communities (Capital Adequacy of Credit Institutions) Regulations 2006 / under regulation 72.3. The following qualitative disclosures are made in conformance with these regulations unless the disclosure is regarded as immaterial or proprietary or confidential.

1. Disclosures

All risks identified by the Company are addressed below. Other risks not addressed are considered to be not applicable or immaterial.

1.1 General requirements Part 2:

Scope of application of the directive requirements

The Company is registered in Ireland and authorised by the Central Bank of Ireland. The nature of the Company's business is investment management, the risks to which the Company is exposed is principally this of an operational nature and managed according to the internal guidelines. The Company is a EUR 125,000 licensed company and lodges its accounts with the Companies Registration Office. (Company Registration no. 379485)

There is no deficit of capital.

1.2 General requirements Part 3:

Capital Resources

The capital resources of the Company are made up of Ordinary Share Capital and the profit and loss reserve account, where applicable current year losses and dividends are also taken into account. The capital therefore qualifies as Tier 1 capital.

1.3 General Requirements Part 4 and the overall Pillar II rule:

Disclosure compliance

Under Pillar II, the Company is required to enact an Internal Capital Adequacy Assessment Process (ICAAP). This is an ongoing process. The ICAAP document is presented to the Board of Directors of the Company for formal review and approval. The data and assumptions used in the assessment of risk and capital adequacy are continually assessed and updated. Should new risks materialise or be identified by the Company, then these risks are incorporated into the overall review process.

As an investment manager the major risk the Company is exposed to is operational risk. There is also additional exposure to credit and reputation risk.

1.4 General Requirements Part 5 and Part 6:

Counterparty credit risk exposures and credit risk and dilution risk.

1.4.1 The Company adopts the standardised approach to credit risk.

The Company has the following exposures:

- Prepaid vendors

- If a fund or funds became insolvent then fees owing might be irrecoverable.

- Excess funds are placed with the Company's bankers and are therefore exposed to counterparty risk.

Specific procedures are in place to cover these exposures including prompt collection of outstanding fees and placing of excess funds with OECD credit institutions.

1.4.2 Definition of Past Due and Impaired (Part 6.a & g)

The Company has a definition of "Past Due" and "Impaired". Past Due for fees is defined as remaining unpaid 60 days after the payment date. Impaired is defined as where the Company has determined that the debt is past due and there is a specific risk that the amount due is partially or fully unrecoverable.

No past due exposure

1.4.3 Value adjustments and provisions (Part 6.b & h)

Not considered material

1.4.4 Total amount of exposures after accounting offsets as at 31 December 2010

More information provided on request

2010

More information provided on request

2009

More information provided on request

1.4.6 Residual Maturity Breakdown (Part 6. f)

All exposures are current and fall due within one year.

1.4.7 Effect of Credit and Market Risk on Capital Adequacy

The capital requirement of the Company is the higher of the fixed overhead requirement and sum of the large exposure, market and credit risk. For the purpose of this calculation disclosures relating to credit and market risk are considered to be immaterial in consideration in the assessment of the business.

1.5 General Requirements Part 7 to 10: Disclosure on Calculation of counterparty risks.

The Company uses the standardised approach under Basel II.

1.6 General Requirements Part 11: Disclosure of Operational Risks

a) The Company is a EUR 125,000 licensed Company, is registered with the Central Bank of Ireland and calculates its capital adequacy using 3 months operating expenses as a reference as determined by the Central Bank of Ireland.

b) Policies and standards: The operational risks are covered by the underlying operational procedures to ensure the Companys processes and controls operate correctly and effectively.

- Assessment process: There are a number of stages to the operational risk assessment process which includes: Risk identifiers including financial and non-financial events, metrics as well as audit reports.

- The Board of Directors of the Company meets on a regular basis and discusses operational risks at these meetings.

1.7 General requirements Part 12: Disclosure of exposures to Equities

The Company does not have any equity exposures.

1.8 General requirements Part 13: Disclosure of exposure to interest rate risk

The Company does not trade on its own account and therefore does not create any market risk, including interest rate risk in respect of its own business apart from risks on deposits with OECD credit institutions under 12 months.

Fees may be received in multiple currencies that require conversion to EUR for payment to the Company. The overall level of fees received in currencies other than EUR is under 6% and is not hedged.

These disclosures were approved by the Board of Directors on 18 July 2011.