ANTI-MONEY LAUNDERING REQUIREMENTS

The USA Patriot Act requires all financial institutions to obtain, verify and record information that identifies each person who invests as a way of assisting the government in fighting the funding of terrorism and money laundering activities.

VCM Global Asset Management Ltd. and its affiliates (“VCM Global”) have a set of sound Anti-Money Laundering (AML) procedures that allow VCM Global employees to make informed decisions as to whether a transaction with an investor may involve money laundering or may finance improper or illegal activities.

Based on the type of clients we engage with and the illiquidity and duration of most of our investment opportunities, it is our assessment that the risk of money laundering across our business is relatively low. Nonetheless, we are conscious of the need to be cautious and are aware of the obligations and challenges posed by money laundering. We have implemented due diligence procedures to ensure compliance with AML requirements.

When undertaking customer and beneficial owner due diligence, we will ask investors for their name, address, date of birth, social security number and other information that will allow us to identify them. We may require further due diligence to verify investors, such as a check against lists of suspected terrorists and an assessment of whether the amount invested in commensurate with the source of wealth and funds. AML procedures may be handled in-house or, where appropriate, outsourced to regulated service providers in the relevant jurisdiction.