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Describe your trading process.

Market prices are reviewed and in most cases, competitive quotes are sought from two or more
counterparties, agency brokers or market makers. For transactions in less liquid markets and if not
detrimental to the funds’ interests, a single counterparty may be approached on the basis of that
counterparty’s suitability for the transaction. Most of the transactions are traded over the counter on a net
basis.
The long experience of Atlanticomnium in the industry has helped them build relationships with major
investment banks, other industry analysts, fund managers, company managements, specialist brokers,
industry consultants and other respected sources. This enables them to have access to insightful
information, which provides them with the best available trading prices, in accordance with the best
execution policy.
Then orders for GAM funds are nearly always given to the broker with a price limit. The broker confirms to
Atlanticomnium S.A.’s back office and the custodian (State Street). Atlanticomnium verifies and
communicates the trades to GAM, upon confirmation for independent validation upon execution. Only
upon validation are the transactions accepted. GAM then instructs the custodian to settle the trade. There
are two pre-trade risk and compliance checks and one post trade compliance check. These checks are
conducted independently of the investment team, operations and risk teams in the order management
system.
Transactions are monitored for prices against independent data regularly as well as any limits or size to
ensure they comply with both the stated instructions of the manager and the requirements of the funds’
prospectuses and UCITS regulations.

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    The material contained herein is aimed at sophisticated, professional, eligible, institutional and/or qualified investors/intermediaries who have the knowledge and financial sophistication to understand and bear the risks associated with the investments described.

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