Order Execution

Qualitative Disclosure Report – Spinnaker Capital Limited (the “Company”)

This report applies to all classes of assets transacted by the Company for its clients.

Summary of the analysis and conclusions the Company has drawn from its monitoring of the execution quality obtained in the previous year:

In order to determine and monitor the quality of execution, the Company takes into consideration both direct costs and indirect costs. For direct costs, the main considerations are pricing and execution fees. For indirect costs, the main considerations are speed of execution, likelihood of execution, and method of execution (which determines the market impact of the order).

In reviewing the execution results for the past year, the Company has determined that it has taken sufficient steps to obtain the best possible result for its clients. The Company will continue to review its order execution processes and procedures on a regular basis to ensure that it continues to obtain the best possible result for its clients.

Description of any close links, conflicts of interests, or common ownerships with respect to any execution venues used by the Company:

None

Description of any special financial arrangements between the Company and any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received:

None

Explanation of any change in the list of the Company’s execution venues (as set in the Order Execution Policy):

None

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