1. TCF outcomes

Cardale Asset Management Ltd ("CAML") is committed to acting at all times in its clients' best interests.  We believe that clients are the most important part of our business and endeavour to provide a service that is consistent with what they want and expect.

CAML has taken steps to ensure that TCF is embedded in its culture and activities.  The CAML Board is very clear that fair treatment must be at all times applied to our clients in the course of our dealings with them and on their behalf.  For this reason, TCF is the ultimate responsibility of Cardale's Managing Director.

We have focussed on delivery of the FSA's six TCF "customer outcomes" as they apply to our firm, namely:

(1) Our clients can be confident that in dealing with us their fair treatment is central to our corporate culture;

(2) Our services seek to meet the needs of each individual client and are targeted appropriately;

(3) Our clients are provided with clear information and are kept appropriately informed as long as they remain a client of CAML;

(4) On the occasions where our clients receive advice, the advice is suitable and takes account of their circumstances;

(5) Our clients are provided with a service which is of an acceptable standard and is as they have been led to expect;

(6) Our clients do not face unreasonable barriers to inhibit moving to another firm, submit a claim or make a complaint.

In addition, we aim to ensure that CAML staff:

• Remain at all times trained and competent to do their jobs.

• Have a clear understanding of the importance the Board places on TCF.

• Are friendly, helpful and efficient.

TCF is a continuous process included in all relevant business decisions and subject to regular review at Board level.

2. Supporting Policies

CAML applies a number of policies and procedures designed to achieve the above outcomes including:

• Board procedures which include TCF as a regular Agenda item.

• Recruitment and training procedures which include consideration of TCF.

• An account opening process which ensures that investment managers seek to obtain the necessary information regarding clients' circumstances on which to base suitable advice and make suitable investment decisions.

• A conflicts of interest policy, inducements policy and investment research policy, included as separate clauses in our Client Agreement and Terms of Business document.

• Personal Account dealing policies plus salary and bonus structures designed ensure that the personal interests of our staff do not conflict with clients' interests and to promote the importance of TCF in formulating remuneration rewards.

• Risk warnings that are clear and easy to understand.

• Internal mechanisms to independently monitor and enforce our TCF policies and procedures (see 3 below).

• An Investment Committee which regularly reviews CAML's investment decisions and asset allocations.

3. Compliance Arrangements

CAML has a dedicated independent compliance resource tasked with testing on a regular basis the firm's achievement in all key areas of regulatory compliance.

4. Complaints Procedure

In the unfortunate event any of our clients should feel it necessary to complain about any aspect of our service CAML adheres to the fundamental requirements of handling client complaints i.e. prompt and fair investigation, adjudication and communication with complainants.  On acknowledgement of a complaint, we will send the complainant a copy of the CAML Complaint Handling Procedures.

All complaints received are referred immediately to the Compliance Director who is responsible for:

• ensuring the firm's complaints procedures are followed;

• ensuring that the CAML Board of Directors are provided with management information on the number and type of complaints received; and (if applicable)

• conducting root cause analysis to ensure defective systems and controls are suitably improved.