Anti-Money Laundering/Anti-Terrorist Financing (“AML/ATF”) Policy Statement

First Bermuda Securities is committed to preventing the use of its business and operations for money laundering or any other activity which facilitates money laundering, the funding of terrorist or criminal activities, or other financial crimes. FBS will comply with all applicable laws and regulations designed to combat money laundering activity and terrorist financing as well as regulatory guidance notes applicable within Bermuda and any other jurisdiction where it may conduct business. To that end, FBS:

•  Reports suspicious activities to the appropriate local authorities

• Cooperates with legal and regulatory authorities if and when requested

• Provides regular AML/ATF awareness training to staff including delineation of procedures for identifying unusual and potentially suspicious activity, and reporting such activity to the authorities

• Records and maintains client transaction data for the appropriate retention period of time

• Monitors clients’ and prospective clients’ activities on an on-going basis

• Only accepts clients whose identity is clearly established by conducting due diligence appropriate to the risk profile of each client

• Maintains procedures that require the collection of information in order to verify the identity of each new client

• Designates a person responsible for ensuring FBS compliance withe its AML/ATF policies and procedures, and

• Maintains an AML/ATF policy that covers all types of FBS activity and clients of FBS.

FBS has developed and maintains AML/ATF policies and procedures. These provide the basis to further develop and update when necessary the specific policies and operational procedures with respect to each of its activities. The individual designated responsible for FBS compliance with its AML/ATF policy reports to the Chief Executive Officer, who in turn reports to the FBS Board of Directors.