Conflict of Interests Policy

VSA Capital Limited (“VSA”) is authorised and regulated by the Financial Services Authority (“FSA”) and is required to adhere to the principles and rules imposed by the FSA in relation to conflicts of interest. In particular we must have regard to Principle 6 which requires us to pay due regard to the interests of our customers and treat them fairly; and Principle 8 which requires us to manage conflicts of interest fairly, both between us and our customers and between different customers. In addition VSA must meet the detailed requirements of SYSC 10 and COBS 12. This document describes our policy in relation to the identification and management of conflicts of interest and has been approved by the Board of Directors of VSA.