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Conflicts of Interest

CONFLICTS OF INTEREST POLICY

We are required to inform investors of any conflicts of interest that may affect the services we provide.  We maintain a series of conflict management policies and procedures which mandate when and how we disclose conflicts of interest to investors. As a guiding principal, we will consider a conflict of interest to be any circumstance where the Funds have relationships with related or connected issuers; the Funds have a relationship with other issuers; there are competing interests between the Funds and investors; RSAM Directors serve on the Board of Directors of another entity; employees have outside business activities; or the Funds employ certain compensation practices.

When responding to any conflict of interest, we will consider our standard of care for dealing with investors and apply consistent criteria to similar types of conflicts of interest. In determining the appropriate course of action to respond to conflicts of interest, we will determine whether to alleviate the conflict using avoidance, control or disclosure.