The fund will manage portfolio and investment risk through a combination of measures, including:

• Dedication to a formal, thorough, documented and consistent allocation process whereby all investment allocation decisions are vetted and approved by all portfolio managers and at least one Fund officer
  
• Strict adherence to an established set of accounting controls and policies
  
• Benchmarking the fund to an established and well regarded index in order to maintain a risk profile similar to that of the index and to provide a meaningful measure of the fund’s investment success
  
• Thoroughly analyzing long and short weightings relative to the index and actively monitoring the fund’s actual and estimated (prospective) tracking error relative to the index.  The fund’s target estimated and actual tracking error is 5%, however, the target is not strict and the fund’s actual and estimated tracking error may exceed 5%
  
• Limiting the fund’s exposure to any single position by maintaining both a maximum percentage weighting as well as a maximum deviation from that stock’s weight within the benchmark index