ÿþ<html><head><META http-equiv="Content-Type" content="text/html; charset=utf-16"><TITLE>Marco Polo Pure Asset Management</TITLE><meta http-equiv="Pragma" content="no-cache"><link rel="stylesheet" href="tdc1.css" type="text/css"><script language="JavaScript1.2" src="tdc.js" type="text/javascript"></script></head><BODY topmargin="0" leftmargin="5" class="B2BBodyBg" bgcolor="FFFFFF"><table id="contentBody" width="100%" border="0" cellpadding="0" cellspacing="0" style=""><tbody><tr valign="top"><td width="100%"><table width="100%" border="0" cellpadding="0" cellspacing="0"><tbody><tr valign="top"><td><table width="100%" border="0" cellpadding="0" cellspacing="0"><tbody><tr valign="top"><td><table id="___01" height="487" cellspacing="0" cellpadding="0" width="820" border="0"><tbody><tr><td valign="top" width="249" rowspan="3"><img height="487" src="http://marcopolo.intimexptx.com/e/customize/images/cat_01_legal_01.jpg" width="249"></td><td colspan="2"><img height="155" src="http://marcopolo.intimexptx.com/e/customize/images/cat_01_legal_02.jpg" width="571"></td></tr><tr><td colspan="2"><font face="Arial"><img height="24" src="http://marcopolo.intimexptx.com/e/customize/images/cat_01_legal_03.jpg" width="571"></font></td></tr><tr><td width="47" height="487"><font face="Arial">                    </font></td><td valign="top" width="524" height="487"><p align="justify"><font face="Arial"><br>Use of this website indicates that you have agreed, and you will be deemed to have agreed, to the statements set forth in the Legal Disclaimer, and also indicates your acknowledgement of the information contained within the section on Regulatory Information.</font></p><p align="justify"><br><font face="Arial"><strong><font color="#621C1E">Legal Disclaimer</font></strong><br><br>The information contained on this website has been prepared by Marco Polo Pure Asset Management (Cayman Islands) Limited (the  Marco Polo Pure Asset Management ) for information purposes only and is highly confidential. The information contained in this website has been compiled from sources, including publicly available sources and private databases, which Marco Polo Pure Asset Management believes to be accurate. However, no attempt has been made to verify its accuracy. Neither Marco Polo Pure Asset Management, any fund Marco Polo Pure Asset Management manages (the  Funds ), nor any of their respective directors, officers or employees accept any responsibility whatsoever for the accuracy or completeness of such information and therefore no reliance should be placed on such information. In addition, Marco Polo Pure Asset Management, the Funds and their respective directors, officers and employees expressly disclaim and will not accept any liability whatsoever (in negligence or otherwise) for any loss howsoever arising from any use of this document or its contents or otherwise arising in connection therewith. <br><br> The information contained in this website may not be copied, whether in whole or in part, or transmitted or distributed to third parties without the prior written consent of Marco Polo Pure Asset Management. Access to the information contained on this website may be restricted by law, and persons who access or attempt to access it should inform themselves about, and observe, any such restrictions. <br><br> Investment returns and the value of an investment will fluctuate so that the value of an investment may be less than its original cost. There is no guarantee that in any time period, particularly in the short term, an investment will appreciate. Investors may lose all of their investment. Any reference to historical performance herein, does not guarantee future results. <br><br> The contents of this website should not be construed as investment, legal or tax advice and readers should consult with their own counsel, accountants and other advisors.</font></p><p align="justify"><br><font face="Arial"><font color="#621C1E"><strong>Regulatory Information</strong><br></font><br>The information contained on this website does not constitute a prospectus, an offer or an invitation to subscribe for any securities, or a recommendation in relation to any securities. In particular, the information does not constitute or form part of any offer of the shares of any Fund ( Shares ) or an invitation to apply for any Shares. The subscription for any Shares may only be made on the basis of the relevant Fund s offering memorandum (an  Offering Memorandum ). <br><br> It is your responsibility to inform yourself of and observe any relevant restrictions your jurisdiction of residence. <br><br> In particular, the Funds are not authorized by the Securities and Futures Commission in Hong Kong and no Shares may be offered or sold to investors in Hong Kong other than to persons whose ordinary business it is to buy or sell shares or debentures, whether as principal or agent, or in other circumstances which do not constitute an offer to the public for the purposes of the Hong Kong Companies Ordinance or the Hong Kong Securities and Futures Ordinance. <br><br> The Shares have not been and will not be registered under the United States Securities Act of 1933, as amended (the  Securities Act ) and may not be offered or sold in the United States or to U.S. Persons unless the investors are  accredited investors as defined in Regulation D adopted under the Securities Act. The Funds have not been and will not be registered as an investment company under the Investment Company Act of 1940, as amended (the  Investment Company Act ). The Shares are offered subject to the exemption provided by Section 3(c)(7) under the Investment Company Act and may only be offered or sold in the United States to persons who are  qualified purchasers under the Investment Company Act. <br><br> Persons considering an investment in any Fund are encouraged to consult their professional advisors before deciding to invest. <br> Marco Polo Pure Asset Management is registered as an investment adviser under the US Investment Advisers Act of 1940, as amended (the  Investment Advisers Act ) with the US Securities and Exchange Commission (the  <em>SEC</em> ). However, having its principal office and place of business outside the United States, Marco Polo Pure Asset Management is not obligated to comply with certain requirements of the Investment Advisers Act in respect of any Fund. The direct or indirect ownership of any Shares by US Persons (as in the Securities Act) is permitted only with the consent of Marco Polo Pure Asset Management. Marco Polo Pure Asset Management is exempt from registration with the US Commodity Futures Trading Commission (the  <em>CFTC</em> ) as a commodity pool operator ( CPO ). Therefore, unlike a registered CPO, Marco Polo Pure Asset Management is not required to deliver a disclosure document (as defined under CFTC regulations) to any participant in any Fund. Any registration or filing with any regulatory body does not imply that any such regulatory body has approved the Manager or the Company.</font></p><p align="justify"><br><font face="Arial"><strong><font color="#621C1E">NEW ACCOUNT PROCEDURES</font></strong><br>To help fight the funding of terrorism and money laundering activities, US, Cayman Islands and other law require all financial institutions to obtain, verify, and record information that identifies each person who opens an account. <br> What this means for you: When you open an account, you will be asked for your name, address, date of birth and other information that will allow for verification of your identity. You will also be required to submit a passport or identification card. <br></font></p><p align="justify"><font face="Arial"><strong><font color="#621C1E">PRIVACY POLICY</font></strong><br></font><em><br><strong><font face="Arial" color="#621C1E">We are Committed to Protecting Personal Information</font></strong></em><strong><br></strong><br><font face="Arial">At Marco Polo Pure Asset Management and at each of our related companies, the privacy of the information you provide is important and you can be assured that your privacy will be protected. <br> This Privacy Policy outlines the types of information we gather about you, how we use it and with whom we might share it. We urge you to read this Privacy Policy so that you will understand our commitment to you and to your privacy. <br></font><strong><br><font face="Arial"><em><font color="#621C1E">The Types of Personal Information We Collect</font></em><br></font></strong><br><font face="Arial">In order to provide you with the highest level of service possible, it is necessary for us to collect and maintain certain personal information about you. We collect this information from applications and other forms, from your dealings with us and others. Depending upon the services and products you have requested or for which we have been asked to provide, we may also receive information from consumer reporting agencies and other sources such as our website. <br> The types of information we collect and maintain may include:</font></p><div align="justify"><ul><li><font face="Arial">Information contained in applications and other forms including your name, address, social security number, family member information, beneficiaries, assets and income;</font></li><li><font face="Arial">Information concerning your relationships with us such as products or services purchased from us, account balances and transactions and payment history; and</font></li><li><font face="Arial">Information from visits to our website such as site visitor data, and online data collection devices known as "cookies"</font></li></ul></div><p align="justify"><strong><em><font face="Arial" color="#621C1E">How Personal Information is Used</font></em></strong><strong><br></strong><br><font face="Arial">We use personal information in ways that are compatible with the purposes for which we originally requested it. We may use your personal information for the purpose of processing your requests and transactions, offering or furnishing additional products and services or to evaluate your financial needs. We do not share your personal information with unaffiliated companies except as provided in this notice. <br> In order to provide you with the appropriate level of service, we may share account and transactional information among related companies of Marco Polo Pure Asset Management. We may also share personal information described above with firms that assist us in carrying out your needs. For example, we may share your personal information for specific business purposes with the following companies:</font></p><div align="justify"><ul><li><font face="Arial">Financial service institutions, such as securities brokers, and banks, with whom we have joint marketing agreements; and</font></li><li><font face="Arial">Companies under contract to perform services for us or on our behalf (such as fund administrators, vendors providing data processing, computer software maintenance and development, transaction processing and marketing services.</font></li></ul></div><p align="justify"><font face="Arial"><em>Marco Polo Pure Asset Management does not sell personal information to anyone.</em> Additionally, we treat the personal information of our former clients in the same manner as we treat the personal information of our current clients. <br> We also reserve the right to disclose your personal information in certain circumstances where we feel that disclosure is required by law, to assist law enforcement officials or officials of regulatory agencies, to perform credit checks or collect monies owed to us, and to protect our rights and property.</font></p><p class="style12"> </p><p><br></p></td></tr></tbody></table></td></tr><tr><td></td></tr></tbody></table></td></tr></tbody></table></td><td height="100%"><table border="0" cellpadding="5" cellspacing="5" width="100%"></table></td></tr></tbody></table></BODY></html>