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What is the MIFID?

The MIFID is new regulations developed at the European level, whose main aim is to provide better protection for investors. The Markets in Financial Instruments Directive 2004/39/CE was transferred to Spanish legislation by means of Law 47/2007 and Royal Decree 217/2008 and compliance has been mandatory for all entities since 1 November 2007. The regulations apply only to some products, such as variable-income stock, fixed-income assets and money markets, investment funds and exchange-traded and OTC market derivatives. Main aims

The main aims of the directive are: 1) to complete the single financial services market for the EU. 2) to respond to changes and innovations with regard to market security. 3) to protect investors. Adaptation of Capital Strategies Partners, A.V. S.A. to the MIFID

As a result of Capital Strategies Partners, A.V. S.A. being approved by the National Security Exchange Commission (CNMV in its Spanish acronym) as a brokerage house, we are involved in a process of adapting to and complying with the directive. As part of this process, the agency has developed an adaptation plan together with Gomarq Consulting, S.L. This plan is based on the following aspects:

1. Uninterrupted business policy

2. Register keeping policy

3. Client categorization policy

4. Information on management of conflicts of interest

5. Pre-/Post-contractual information and information rights

6. Incentive policy

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1. Uninterrupted business policy

The aim of this is to guarantee continuation of the business and establish a plan for covering other risks, regardless of whether these may or may not halt the activity of the company. The design of the Uninterrupted Business Policy enables the brokerage not to halt its activity in the face of disasters or serious circumstances. In particular, the aim is to guarantee the following in the event of an interruption in services and procedures:

That essential information and functions will be retained.

That investment services and activities will be maintained.

When the preceding is not possible, the timely recover of said information and functions and the timely resumption of investment services and activities.

2. Register keeping policy

Article 13 (6) of Directive 2004/39/CE stipulates that all investment companies must keep a register of all services and transactions they carry out. Said register must be sufficient to enable the proper authority to supervise compliance with the requirements envisaged in the present directive and especially, with all obligations of the investment company with regard to its clients or possible clients. 3. Client categorization policy

All of the company’s current and potential clients must be classified as “retail”, “professional” or “eligible counterparty”. This classification indicates the level of protection for each client, as envisaged in current regulations, and therefore, the relationship which must be maintained between the company and each type of client. Because of the type of business we have been carrying out to date, all of our clients, duly regulated financial institutions, have been classified as “eligible counterparty”. In any event, clients may expressly request a change of client classification. Said request must be supported by evidence and will subsequently be evaluated and approved by Capital Strategies Partners, A.V. S.A. (Appendix 1).

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4. Information on management of conflicts of interest

Capital Strategies Partners, A.V. S.A. has defined and approved a Conflict of Interest Policy. The aim of this is to identify situations which may potentially create a conflict of interest between the entity and its clients or amongst various clients, in order to establish the procedures or measures designed to prevent this conflict. As a last resort, said situations are to be reported to clients in those circumstances in which conflicts cannot be avoided. The aforementioned policy establishes rules intended to guarantee that clients’ interests are not harmed by the potential appearance of conflicts of interest. With the previous aim, we have adopted a Conflict of Interest Prevention and Management Policy, whose content is based on three elements: I. Implementation of Internal Conduct Rules which are mandatory for the entity’s personnel

and third parties which may generate a conflict of interest. II. Management measures for the associated transactions. III. Measures intended to maintain a suitable level of independence and separation between

the company’s functions. 5. Pre-/Post-contractual information

The aim is for Capital Strategies Partners, A.V. S.A. to make available to clients the information necessary to make investment decisions and be informed of the status of both their transactions and investments. At the same time, it will periodically send information published by managers to institutional clients by means of the established channels. As regulated in Section 2, Art. 19 of the MIFID, the entity must act with honesty, impartiality and professionalism in the best interest of its clients. 6. Incentive policy

Capital Strategies Partners, A.V. S.A. shall receive from its clients the commissions, expenses and fees which in each case correspond to those established in the Rates Brochure currently in force, approved by the CNMV and available at all the company’s offices, as well as on the website of this organization. As part of the service of marketing collective investment entities, the agency shall not directly receive any commission whatsoever from the client. The cases of incentives from third parties received by the agency are listed in the following table:

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Related service:

1. Distribution of investment funds qualified investors.

Item Approximate amount

Basis of calculation

CSP receives from the fund manager a percentage of the management fee. Maximum: 50%

Of the management

Fee

CSP receives from the fund manager a percentage of the initial amount subscribed by the client (up-front fee, applicable to certain funds)

Maximum: 0.20%

Of the amount invested

CSP receives from the fund manager a percentage of the amount of the investment held over a certain period of time (bonus fee, applicable to certain funds)

Maximum: 0.10%

Of the amount invested

2. Distribution of structured products to qualified investors.

Item Approximate amount

CSP receives from the structuring entity a percentage over the amount invested. Maximum: 4,00%

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3. APPENDIX 1

REQUEST FOR CHANGE OF MiFID CLIENT CATEGORY Name and surname/Registered name, with tax identification number (DNI/CIF) xxxxxx, by means of the present, acknowledges that xxxxxxx xxxxxxx xxxxxxx (hereinafter XXX) has duly informed in terms of time and method the same of the client category which has been assigned, as well as the right to request a different categorization and the implications of this within the applicable rules for protection, of which the same is fully aware, and requests, for all investment services which XXX may provide for any type of financial instrument, the change of categorization of which the same has been informed under the terms and conditions established in the present request. Type of change requested: (mark the appropriate option with an “x”). 1. To less protection: (for which XXX will evaluate compliance with the requirements established by the MiFID and inform the client of the result) � From retail client to professional client Case 1 For which I declare that I meet at least two of the following conditions:

� 1.- Have carried out transactions of a significant size in the appropriate securities market with an average frequency of at least 10 per quarter during the preceding four quarters. � 2. That the value of my financial instruments portfolio made up of cash deposits and financial instruments is greater than 500,000 euros. � 3. That I hold or have held for at least one year a professional position in the financial sector which requires knowledge of the transactions or services provided.

Case 2

That with regard to the last accounting year closed, I meet at least two of the following conditions: � Total assets > 20 M � Annual Turnover > 40 M � Own Resources > 2 M � From professional client to eligible counterparty For which I declare that I belong to at least one of the following groups: � Financial institutions and legal entities authorized by regulatory bodies to operate in financial markets.

� Institutions which form part of the government administration, central banks, international and supra-national organizations.

2. To more protection: (this change will be made directly, with the simple request of the client and their signature being sufficient) � From professional client to retail client � From eligible counterparty to professional client Date: Signed: