DUE DILIGENCE QUESTIONNAIRE - Creative Wealth Solutions · 2014-10-21 · DUE DILIGENCE QUESTIONNAIRE Lancelot Global PCC Swiss Asset Micro Assist Income Fund (SAMAIF) (USD/GBP/EURO)

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DUE DILIGENCE QUESTIONNAIRE Lancelot Global PCC

Swiss Asset Micro Assist Income Fund (SAMAIF)

(USD/GBP/EURO)

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DOCUMENT GUIDELINES

The purpose of this document is to serve as a guide to professional advisors. Most fund strategies are more of an investment nature rather than one of trading activity. Each strategy has its own peculiarities. The most important aspect is to understand clearly what you plan to promote. Not all of the following questions are applicable to all professional advisors.

IMPORTANT

The copyright in this questionnaire belongs to Belvedere Management Limited. You may copy the questionnaire for your own company’s use, but you may not distribute or copy it for any other purpose or to any other person, including any representative of the media, without the prior written consent of Belvedere Management Limited which will only be given in exceptional circumstances. If you wish to share the questionnaire with others, please provide their details to Belvedere Management Limited.

DISCLAIMER

Whilst Belvedere Management Limited has used all reasonable efforts to produce a questionnaire of general application in connection with a due diligence appraisal, in any particular case a professional advisor is likely to have its own individual requirements and each fund its own characteristics. As a result, it is strongly recommended that the questions are reviewed in full to gain a full understanding of the fund manager's operations.

In addition, responses to the questionnaire should not be relied upon without review and, where considered appropriate, further investigation. In order to obtain the best possible information on any specifics of the fund additional questions should be raised to clarify any point of uncertainty, and where practicable verbal examination should be undertaken. In particular, Belvedere Management Limited recommends that in respect of special areas of concern, such as fund performance or risk profile, independent third party data should, if possible, be obtained in order to verify these facts.

Accordingly, none of Belvedere, its officers, employees or agents makes any representation or warranty, express or implied, as to the adequacy, completeness or correctness of the questionnaire. No liability whatsoever is accepted by Belvedere Management Limited, its officers, employees or agents for any loss howsoever arising from any use of this questionnaire or its contents or otherwise arising in connection therewith.

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CONTENTS

• Manager Information…………………………………… 4 - 5 • Fund Information………………………………….…… 6 - 8 • Data Overview……………………………………….…. 8 - 9 • Strategy………………………………………….……..10 - 13 • Risk……………………………………………………..14 - 15 • Investment Research…………………………..………… 16 • Investor Service/Reporting ……………………………… 17 • Administration ……………………………………………. 18

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MANAGER INFORMATION

CONTACT INFORMATION

Company name: RDL Management Ltd Address: 4A, 4th Floor, Ebene Mews, 57 Ebene Cybercity, Ebene, Mauritius Telephone: (230) 466 9700 / (230) 736 4889 Fax: (230) 466 9702 E-mail: [email protected] Name of contacts: David Cosgrove Title of contacts: Director Telephone of contacts: (230) 736 4889 E-mail of contacts: [email protected]

COMPANY

Please give a brief history of the firm:

RDL Management Ltd is a company incorporated in Mauritius and regulated by the Mauritian Financial Services Commission as an investment advisor and collective investment scheme manager.

Legal entity: Yes Domicile: Mauritius

Branch offices or other locations, if any: • What functions are performed at

these branches and locations?

Belvedere Management Limited acts as the administrative office to the manager and it is located at 7A 7th Floor Ebene Mews 57 Ebene Cybercity Ebene Mauritius.

Which regulatory authority is the company registered with?

• Type (class):

• Date of registration: • Are all the employees registered

with the same authority?

The Mauritian Financial Services Commission

08 January 2007

List any affiliations, directorships and memberships of the company and/or it’s principals:

David Cosgrove and Frances Henriette are the current directors of the company.

COMPLIANCE

Who is responsible for compliance in the firm? Vishal Munisami

Please describe any current or potential conflict of interest:

No conflict of interest

Does the firm or advisor have any relationship, which may affect its trading flexibility, e.g. associated broker/dealer?

No

Please list your accountant and attorney of the company:

Jean Denis Michel as accountant and C&A Law as Legal Adviser

Is there any material, criminal, civil or administrative proceedings pending or threatened against the firm or any of its principals, or have there ever been any such matters?

• If yes, please provide full details:

No

N/A

What are the firm’s employee own account dealing procedures?

All share dealing needs to be approved prior to the trades being placed

Do any of the firm’s principals have other business involvement?

Yes they have stakes in other financial services companies

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• If yes, describe and quantify how much of their professional time is dedicated to each?

Variable as this depends on demands

MANAGER ORGANISATION

How large is the firm in terms of full time individuals?

RDL currently employs 3 full time senior staff. Total group employees in Mauritius is 69 (accountants, lawyers, investment professionals and administrators).

Describe the firm’s ownership structure, name of its owners, their percentage ownership, and their role within the firm?

The firm is owned by David Cosgrove and Jacobus Everhardus Kellermann with 50% ownership each. David Cosgrove is the director of the firm and Jacobus Everhardus Kellermann acts as the portfolio manager of the funds which the firm manages.

Percentage ownership of principals? 50% each Short background of principals (education, career background, etc.)

• Please, attach information if necessary

CV’s available upon request.

How many investment professionals (portfolios managers, analysts, etc) in the firm?

3

What are the average years of professional experience in the firm, both years as a professional as well as years in the firm?

Dc Cosgrove 25 years and Jacobus Kellermann 14 years

Please give the names of senior managers in charge of the following areas:

• Trading:

• Reporting, performance analysis:

• Research and development:

• IT/Programming:

• Administration:

• Marketing and business development:

• Others (please specify):

David Cosgrove

Jacobus Kellermann David Cosgrove and Jacobus Kellermann Sachin Bundhoo of Legendary Technologies Rani Jeebun David Cosgrove

What has been the turnover rate among the firm’s personnel?

No staff has ever resigned

Where do the primary trading, research, and portfolio management activities take place?

The registered office is at 4A, 4th Floor, Ebene Mews, 57 Ebene Cybercity, Ebene, Mauritius and the administrative office is at Belvedere Management Limited, 7A, 7th Floor, Ebene Mews, 57 Ebene Cybercity, Ebene, Mauritius

Where are the accounts maintained? Both at the registered and administrative offices Are outside representatives or consultants used for any activities? If so, give details.

No

MANAGER REFERENCES

Please provide at least two references for the firm and for each of the principals involved in the management of the fund?

• Name:

• Profession:

• Company:

• Title:

• Telephone:

• Fax:

• E-mail:

• Current and past relationship with the firm or its principal:

Kenneth Maillard Accountant Belvedere Management Limited Managing Director (230) 466 9700 (230) 466 9702 [email protected] Former director of the firm and provides (Belvedere Management Limited) administrative services to the firm

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Please provide at least two references for the firm and for each of the principals involved in the management of the fund?

• Name:

• Profession:

• Company:

• Title:

• Telephone:

• Fax:

• E-mail: • Current and past relationship with

the firm or its principal:

Laval Law How Hung Accountant Belvedere Management Limited Finance Director

(230) 466 9700 230) 466 9702 [email protected] Director of Belvedere Management Limited

FUND PROMOTERS

What external promoters, if any, have been appointed by the management company for its products?

 N/A

 Duration of your professional relationship?  

FUND INFORMATION

FUND DETAILS

Contact details:

• Name:

• Address:

• Tel:

• Fax:

• E-mail:

• Internet:

• Fund structure:

• Legal entity:

• Domicile:

 Lancelot Global PCC – Cell: Swiss Asset Micro Assist Income Fund (USD/GBP/EURO) 7A 7th Floor Ebene Mews 57 Ebene Cybercity Ebene Mauritius (230) 4669700 (230) 4669702 [email protected] www.belvederemgt.com Lancelot Global PCC is a Collective Investment Scheme. Yes and regulated by the Mauritian Financial Services Commission Mauritius

Date of inception:

26th March 2009 for Lancelot Global PCC and 23rd July 2012 for Swiss Asset Micro Assist Income Fund (USD/GBP/EURO)

Is the fund listed on any exchange(s)? No

FEES

Management fee:

2.0%

Administration fee: 0.3 % Incentive fee: 20% performance fee

Hurdle rate / High water mark:

The High Water Mark is a currency amount per Share equal to the highest Net Asset Value per Share from the date of inception of the Fund to the Performance Date immediately prior to the relevant Performance Date – please refer to the cell appendices.

Sales fee: No Redemption fee: 5% year 1, 4% year 2, 3% year 3, 2% year 4, 1% Year 5, 0% Year 6.

Any other fees: Estimated provision for expenses of the Cell: 0.1% per annum of the net asset value

What costs, if any, are recharged to the fund?

Custody fee 0.1 % per annum , minimum $ 5.000

Do you ever share fees with a third party? Yes

Have any investors been granted rebates? Disclose any soft dollar agreement.

No

LIQUIDITY

Minimum initial investment: $/€/£ 10,000

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Minimum subsequent investment: $/€/£ 1,000 Subscription frequency (when): Weekly Redemption frequency (when): Weekly Redemption notice period: 30 day notice period prior to each Redemption Dealing Day.

Redemption cash proceeds time period:

Payment of the redemption proceeds will be made on or before the fifth Business Day following the applicable Redemption Dealing Day.

Do you have any lock-up period or any other liquidity constraints?

No lock-up period

Do you allow for transfer of shares between nominees?

Yes

ADMINISTRATOR

Details:

• Name:

• Address:

• Telephone:

• Fax:

• E-mail:

• Name of Contact:

• Telephone of contact:

• E-mail of contact:

 Belvedere Management Limited 7A 7th Floor Ebene Mews 57 Ebene Cybercity Ebene Mauritius (230) 4669700

(230) 466 9702 [email protected] Kenneth Maillard (230) 4669700 [email protected]

Duration of your professional relationship? 5 years

AUDITOR

Details:

• Name:

• Address:

• Telephone:

• Fax:

• E-mail:

•

 BDO Mauritius DCDM Building, 10, Frère Félix de Valois Street Port Louis MAURITIUS (230) 202 3000 (230) 202 9993 [email protected]

Duration of your professional relationship? 3 years

CUSTODIAN

Details:

• Name:

• Address:

• Telephone:

• Fax:

• E-mail:

 The Mauritius Commercial Bank Ltd Sir William Newton Street Port Louis Mauritius (230) 2025000 (230) 211 5375 [email protected]

Duration of your professional relationship? 3 years

LEGAL ADVISER

Details:

• Name:

• Address:

• Telephone:

• Fax:

• E-mail:

C&A Law Suite 1005, Level 1, Alexander House, 35 Cybercity, Ebene, Mauritius (230) 466 0500 (230) 464 5401 [email protected]

Duration of your professional relationship?

2 Years

BANKS AND PRIME BROKER

Please list the banks used by the fund: The Mauritius Commercial Bank Ltd

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Please list the prime brokers used by the fund, as well as the duration of your professional relationship:

Citygate Securities Limited

DIRECTORS OF FUND

Please list the number of directors, their names and the degree of relationship with manager and service providers?

2 directors: David Cosgrove shareholder of RDL Mnagement Ltd, and Kenneth Maillard, Managing Director of Belvedere Management Ltd .        

Duration of your professional relationship? Directors since date of incorporation

DATA OVERVIEW

FUND ASSETS

Please list the size of assets by investment vehicle:

Investment 91% - Cash and other assets 9 %

Please list the size of the fund’s net assets: Approximately $ 7.7 m List the total assets under management, and their respective changes over the last year:

Approximately $ 7.7 m + $3.0 m for calendar year 2013

What percentage of assets is represented by the largest investor?

Approx. 4.04%

CAPACITY MANAGEMENT

What is the maximum capacity of your fund?

None – Open ended

What is the projected time frame to reach capacity?

N/A

Will new money be accepted after capacity is reached?

N/A

How will front / back-office operations be affected in the event of significant increase in assets under management, and what measures will be taken?

No effect

WITHDRAWALS

What were the largest withdrawals in your fund since inception?

• Date:

• % of equity:

• Reasons:

March 2014 2.5%

Investor needed cash

MANAGEMENT TEAM’S CO-INVESTMENT

  What is the total amount invested by the principals / management in the fund and other investment vehicles managed pari passu with the fund?

  None

  Has the management reduced its personal investment?

• Date:

• Amount:

• Reasons: Disclose conditions of subscription/redemptions of team and owners’ assets.

  No

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FUND PERFORMANCE

Historical performance since inception:

• Monthly NAV’s since inception (in table format):

• Monthly RoR since inception:

 Per attachment

Per attachment

Please explain any major factors affecting performance and drawdowns (i.e. a manager change, a change in strategy, etc.):

None

Is the fund performance audited? Yes

DRAWDOWNS

  List the 5 maximum drawdowns, in percent of equity for each fund, the recovery period, and explain why they have happened:

  Available upon request

  Over the past 12 months, how many daily drawdowns greater than 5% have occurred, and what was the length of recovery?

  None

MANAGER TRACK RECORD

Number of portfolios / accounts managed by the firm:

8

Number of funds managed / advised by the firm:

Names of these funds:

The Abroad Spectrum Mutual Fund PCC Limited, The Global Mutual Fund PCC Limited, The Universal Mutual Fund ICC Limited, The Worldwide Mutua Fund PCC Limited, The Four Elements PCC, The Two Seasons PCC, Lancelot Global PCC and Venture Assets PCC.

Total assets managed / advised by the firm:

RDL managed funds are circa $500m. The total group assets under administration, management and advisory is circa $16.5bn

Oldest continuously active account:  Largest current account:  Length of track record: 2008 Has the track record been audited: Ernst & Young + BDO What is your level of portfolio turnover?  

STRATEGY

Characterise your investment style in terms of:

Strategy:

Hedging:

Market exposure:

Portfolio concentration: (In terms of

amount of instruments and exposure bias min/max/avg. number of instruments, min/max/avg. long or short bias)

Geographical market focus:

• Strategy:

The Fund offers investors a financially and socially sound investment into microfinance. It offers the prospect of an attractive financial return combined with a chance to make a pro-active, measurable and sustainable contribution to the development of the microfinance sector. Ultimately the aim is to create an inclusive sector in which the majority of people have access to financial services. Investing where there is a combined social goal such as this can sometimes referred to as “impact investing".

• Hedging:

Loans are always denominated in $ which eliminates the need for hedging such positions.

The currency positions between the $, EURO and £ are hedged at the level of the Fund.

• Market Exposure:

Historical loan default rates for Micro Finance are exceptionally low: 10yr MFI loan loss rates: South Asia 0.99%, Africa 2.19%, Latin America & Caribean 2.47%. MFI’s under the control of the Fund outperform these industry averages due to the fact that all loans are collateralized and secured against physical assets. To ensure liquidity, the Fund only invests in Institutions offering loans for typically short periods of time, the current average being 2.8 months and the longest 12 months. To achieve liquidity the Investment Manager seeks to maintain a minimum of 10% of the Fund portfolio in cash or cash equivalents. Up to 50% of the portfolio will be in Loans classed as 3 month redeemable investments

• Portfolio Concentration:

Holding companies, special purpose vehicles (SPV’s), structured notes and other collateralized debt instruments. The target of the Fund is to invest in suitable senior debt, subordinated and/or convertible debt instruments. Where equity investments are made, the Fund will generally seek a controlling stake.

• Geographical market focus:

The Fund targets operations where the availability of Finance, localized loans and Banking for individuals and small enterprises is limited. Areas for focus of the Fund are where the banking industry is underdeveloped and ill-equipped to take advantage of the market potential. The Fund mainly operates in Emerging markets such as: Africa, South America, and Asia.

Confidential For Professional Advisors Only Page 10

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Describe your strategy (in as much detail as possible):

The Fund has identified locally regulated Institutions providing micro finance and short- t e rm loans as a focus for the investment of the Fund’s assets. These institutions may take the form of specific Microfinance Institutions (MFI’s) providing services to Micro Entrepreneurs, Private Individuals, or Small Businesses or Financial Institutions (FI’s) providing financial solutions to Small to Medium Enterprises (SME’s).

The Fund invests into MFI’s and FI’s principally by way of loan capital. The loan capital is used by the Institution to provide short-term customer loans to localized Micro Entrepreneurs, Private Individuals, Small Businesses or SME’s.

Through careful credit management these short- t e rm customer loans are able to deliver consistent double-digit returns to the Institution, in turn the Institution pays an attractive rate of return to the Fund for the capital provided.

The Fund will in most cases take a blocking minority share in the equity of the Institution it invests in. The Fund’s constitution prohibits if from acquiring more than 25% of the total equity issued by a single MFI, or more than 25% of the securities and financing instruments issued by a MFI or equivalent. Exceptions are provided for when control of the MFI has been ceded to the Fund, and during the first year of operations. The Fund may also elect to start greenfield operations such as MFI’s where the location and target market is suitable. All micro loans issued by the Funds greenfield MFI’s are collateralized against assets owned by the local borrower and where possible protected by specific Micro Finance Insurance. In addition, often-personal guarantees are provided by persons close to the borrower. All customers are obliged to take out a life insurance policy.

In many environments where Micro Finance flourishes and is most needed the traditional financial institutions play hardly any role in financing. Local banks will typically shy away from micro finance and local governmental initiatives are often unsuccessful.

In these environments loan sharking is often the only source of finance for borrowers with sometimes detrimental consequences.

It is against this backdrop that SAMAIF is able to offer a genuine benefit to local entrepreneurs who are increasingly in need of credit facilities and financial services products.

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What makes your strategy unique and different from your peers?

-Management team 30 + years combined localised regional

knowledge. - European based management team 100 + years of combined relevant

Industry experience. - Rigorous selection procedure and criteria for selected MFI’s. - Control over MFI’s using blocking minority in the equity with put and

call options or even 100% holding. - Local management selected and screened where the Fund has control. -All loans at Fund controlled MFI’s secured against a physical asset of

the borrower. Currently collateral as security at over 200% of loan values. (as of January 2014), this is a significant and unique factor.

- Hedging of exchange exposures at various levels. - Sophisticated reporting systems with thorough and continuous follow

up on operations. - Sophisticated IT systems that allow for such follow up. - The Fund targets a total annual return for investors, including

dividends, in excess of 8% per annum, with an option to take the dividend income in cash (paid semi-annually) or automatically re- invest.

-50% of loans at Fund controlled MFI’s held in 3 month redeemable investments.

Describe your strategy for today’s market:

One of the primary objectives of the Fund is in delivering a range of financial solutions tailored to the under-served in developing countries and countries in transition. This can include SMEs as well, which in many countries, still lack access to financial services and specifically loans. The Fund will realize this by contributing to the development of Microfinance into a fully-fledged and integral part of the financial sector in developing and transition countries. Generally, the investments of the Fund will be allocated to financial institutions that provide financial services to micro- entrepreneurs and SMEs. If deemed applicable, investment might be in a commercial bank that primarily provides services to SMEs. Such an investment by the Fund might take place when there is a clear market demand locally for financial services to SMEs and a local commercial bank could be deemed best suited to provide these services.

Why do you feel you will generate absolute returns?

The primary focus of the Fund is investment by way of secured short-term loans to operating Micro Finance Institutions. A primary focus of the Fund is the maintenance of short- t e r m liquidity, through management of its loan portfolio. The Fund will seek to make the majority of its investments by way of loan, it is envisaged that this will generate immediate cash flows.

When funds are provided to an MFI, or similar institution, there is always a pledge over the assets of the borrower.

The global market for micro credits, as measured by gross loan portfolio, has grown by a factor of 25x over the last 10-year period. The Micro Finance sector has grown in size every year for the past 12 years.

Returns are stable with a degree of certainty - they are based on fixed interest rate loans to Institutions. There are also arrangement fees and commitment fees. Interest is paid to the Fund annually in advance.

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In which markets do you believe your strategy performs best/worst? (Give examples of time periods):

Volatility: Trends: Liquidity: Correlation:

The focus is on developing countries.

 Please refer “Describe your strategy “ section

What is your average holding period for:

• All investments

• Profitable investments

• Losing investments

N/A

Does the strategy have a long or short bias?

Long term

What investment criteria must new positions meet?

N/A

How do you invest new capital into the market? How do you deal with redemptions?

New Capital - Mostly via loans. Redemptions – Usually from cash reserves, but if more than 10% have option to realize investments with usually up to 50% in 3 month redeemable instruments.

Have the strategy or trading processes changed over time due to capital flows?

N/A

Have you encountered position limit problems? If yes, please explain.

N/A

Describe your cash management policy?  Do you outsource this function? If so, please give name of provider and method used.

No

RISK

LEVERAGE

Discuss your leverage exposure policy and its management over different market cycles:

The fund does not use any leverage to enhance returns.

What are your portfolio financing constraints/limits?

N/A

Discuss sensitivity (cost) to LIBOR levels: None

HEDGING

How is the portfolio hedged? See above How do you determine size and limits for each position/basket?

N/A

How often do you re-hedge? N/A Are short positions profit centres? N/A

DIVERSIFICATION

Discuss the depth of diversification:

Operations are in varied continents and countries with a primary focus on South East Asia, Central Africa and South America. Will invest in, or lend funds to; varied MFI’s & FI’s as well as varied types of projects such as car leasing (principally in the public transportation sector), machinery and equipment leasing, pawn broking which is an activity very close to Micro Finance with collateralized loans.

How do you calculate the correlation between each investment in the portfolio?

N/A

What are the main sources of marginal risk in your strategy?

See: Risk Management

How has performance been distributed across positions and time?

Corporate policy is to distribute funds over a large number of positions that are not related thus reducing the risk of concentration of funds in any particular business, country or sector.

RISK MANAGEMENT

Discuss position and stop-loss limits and their management:

N/A

How often are these limits applied? When were their peaks observed?

N/A

How do you adjust your risk capital allocation when there is a significant increase in equity due to trading profits?

N/A

Do you have a risk manager? Yes Do you use an external risk monitor? If so, who, and why that particular one?

Yes, for currency positions

Please describe the operational risk management policy:

Country risks: The Fund invests in countries classified as transition or developing countries. These countries can be subject to high political risks, they may be in an economic recession with sometimes high and quickly fluctuating inflation rates, with an often poorly developed framework and where standards for auditing and reporting may not be in line with internationally accepted standards. The Fund will always favour countries perceived to have a low level of political risk and competent corporate governance. The corporate policy is not to invest or lend funds to institutions in countries that are, or have recently been, at war, or have known political or economic instability. The investments are continuously monitored by the European Management Team to ensure that any political and economic events are monitored on an ongoing basis.

Confidential For Professional Advisors Only Page 14

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  Institutional risks: The institutions, organizations and vehicles the Fund invests in are generally still young and often experience strong and fast growth. The Fund will mitigate this risk as much as possible in the case of direct investments in MFIs by investing mainly in entities that are regulated and supervised by their countries’ relevant authorities. The investees of the Fund might have a limited track record. Based on the longstanding experience of the Investment Manager, the Fund is properly capable of assessing the various aforementioned risks and taking subsequent investment decisions.

Financial risks: The Fund invests almost exclusively in risk-bearing assets, that are usually secured and that do offer collateral. The return of the Fund may be influenced by developments in the capital markets. Depending on the composition of the portfolio, a change in the interest rates in the capital markets can have a positive or negative effect on the results of the Sub- Fund. The primary focus of the Fund is investment by way of secured short- t e r m loans to operating Micro Finance Institutions. A primary focus of the Fund is the maintenance of short-term liquidity, through management of its loan portfolio. Where the Fund invests in equity these may almost exclusively be in non-stock listed assets, or assets not traded on a regulated market. Such investment may subsequently be relatively illiquid. The valuation of these illiquid, non-listed assets, on a monthly basis may vary substantially from the value realised at time of exit of such assets. There is no guarantee that there are sufficient funds to pay for the redemption of shares of the Fund and there is no guarantee that the redemption can take place at the requested date.

The Fund will seek to make the majority of its investments by way of loan, it is envisaged that this will generate immediate cash flows. Returns on other forms of investments may be generated, or become available for the Fund after a number of years only, especially in the case of equity investments when cash flow and return will only become available after the partial or total sale of those investments. Usually divestments of equity investments will only take place after 5-7 years as a minimum. In case of a major default with an invested entity, the (expected) return may never be generated at all. The Fund has a very specific, sector based investment focus on microfinance and financial inclusion. The associated typical risks of microfinance will be spread to a limited extent only. In the event that there are insufficient investees to invest in, the overall return would suffer as a result of holding too high a proportion of cash.

Currency risks: The Fund may invest up to 90% of its total assets in local currency investments (senior debt, convertible debt and subordinated debt, and equity) with a maximum exposure of 60% of its total assets in unhedged local currency investments. The issued Shares will be denominated in US Dollars. Currency risks for Euro and GBP investments will be hedged towards the US Dollar, and currency risk for local currency investments may be hedged towards the US Dollar to the extent deemed appropriate and possible. The remaining non-hedged investments are subject to currency risk.

Organizational risks: Loss of key personnel.

What system/software is used in your middle office?

In some Fund controlled MFI’s Mambu software is used : www.mambu.com Mambu enables any MFI’s to launch, service and manage loan and deposit products – simply, quickly, and affordably.

EXTERNAL CONTROLS

Are any third parties involved in verifying adherence to risk limits, e.g. the fund’s administrator?

Yes – Belvedere Management Limited and RDL Management.

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INVESTMENT RESEARCH What outside sources are used?

Procedure for investment research:

1. Country Evaluation through a desk research

I. Content a) Demographics b) Political situation c) Education d) Law enforcement (Police, Army) e) Poverty f) Telecommunications g) Economy h) MFI in the specific country i) Containing information on Access to Finance, MF Regulator(s),

MF Regulations, Active MFIs) j) Doing business is in the given target country k) Containing information on Investment Possibilities (Attitude re

foreign investments), Investment Protection, How to start a new business, Taxes,

II. Sources

a) CIA Factbook: https://www.cia.gov/library/publications/the-world- factbook/

b) World Bank publications: http://www.worldbank.org/reference/ c) World Bank country data: http://data.worldbank.org/ d) Center for Financial Inclusion:

www.centreforfinancialinclusion.org e) CGAP (Consultative Group to Assist the Poor):

http://www.cgap.org/ f) IFC ­ Doing Business: http://doingbusiness.org/ g) MF related information: http://www.mixmarket.org/ h) Belgian Ministry of Foreign Affairs (Direct contact with

departments responsible for development and foreign relations) and all Diplomatic services (Embassies, Consulates)

i) Local country’s Ministry of Finance, National Bank, MF regulator (through website, phone and/ or email)

j) Intl’ Audit companies reports on specific region (KPMG, PWC, E&Y)

k) Several other websites found through research

2. Evaluation on the ground

a) Research through existing MFIs b) Contacts with government instances such as Ministry of Finance,

MF regulator, National Bank. c) Contacts with audit companies such as KPMG, PWC d) Contacts with local Belgian Diplomatic service (Embassy,

Consulate) and their Economic Desk(s) e) Market Analysis (investigate areas of potential business, differences

between regions, contacts with potential future customers to investigate other needs, thoughts)

f) Gather information to elaborate BP

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  3. Investment Report discussed in Executive Committee

a) All gathered information is compiled in different documents: b) Business Plan (BP) for local operation c) Total BP d) If applicable BP for each Business Line e) Country Evaluation f) .ppt Presentation of findings (summary of all research done)

What proportion of research is generated internally?

Virtually all initial research is generated and completed internally (See above: (Country Evaluation through desk research, onwards). All regulatory and legal related information is crosschecked and referenced with partners such as KPMG (or other large Audit partners) with renown, local and international legal counsel. They provide in-depth detailed information regarding the constitution of the business and local / country regulations to operate by.

Describe the typical flow of an investment idea from inception to a trading position:

N/A

Describe your back testing of investment ideas?

N/A

Have you published or commissioned any research/academic papers?

No

INVESTOR SERVICE / REPORTING Can the prospectus / offering memorandum be transmitted to us electronically?

Yes

Who calculates the NAV? What is the frequency of calculation?

Belvedere Management Limited Weekly

Can fund performance (NAV, RoR) be transmitted to us electronically on a regular basis, and at what periodicity?

Yes - on a Weekly basis

List all reports and correspondence usually sent to clients, and please explain the frequency and the detail the manager reports performance to investors.

Price updated weekly and displayed on the administrator’s website. Listed

on Bloomberg. Monthly fund fact sheets.

Do you make any adjustments to the NAV valuation received from your source?

No

Can you provide copies of historical reports?

Yes – Upon request

Are investors informed when minor / major changes are made to the trading, money management, or risk control methods?

Yes

What databases, publications, or other available sources does the manager regularly report performance figures to? If none, explain why?

Bloomberg

Can all trades be reported on a daily basis to the client?

N/A

Page 18  

ADMINISTRATION Please indicate any material facts about your fund that are not mentioned in the offering memorandum (domicile, legal issues, political situation, tax etc.)

N/A

Can you link to any third-party risk management systems (like Measurisk)?

N/A

What contingency plans do you have in terms of:

• Computer system fault?

• Incapacitated investment decision

makers?

• Technical failure at Prime Broker’s

location?

• Presence of in-house computer technician?

• Back-up systems?

N/A

QUESTIONAIRE PREPARATION & AND REVIEW: Name:  Date: 17/07/2014 Position:  

DISCLAIMER:

This document is offering information about the Swiss Asset Micro Assist Income Fund – a cell of Lancelot Global PCC and is for information purposes only. The information contained in this document is given without any liability whatsoever to Lancelot Global PCC or any of its related entities or their respective members or officers. The information contained in this document is strictly confidential. This document is not an advertisement and the information contained herein does not constitute investment advice, an offer to sell, or the solicitation of any offer, to buy any securities and or derivatives and may not be reproduced, distributed or published by any recipient for any purpose. It is not directed at or intended for distribution to or use by any person or entity in any jurisdiction where such distribution, publication or use would be contrary to applicable law or regulation. This document should be read in conjunction with the fund prospectus which can be obtained from Belvedere Management Limited, C/O Lancelot Global PCC, 7A 7th Floor, Ebene Mews, 57 Ebene Cyber City, Ebene, Mauritius. The value of your investment may fall as well as rise and is not guaranteed. Past performance is not an indicator of future performance. Changes in exchange rates may cause the value of investments to go down or up. Lancelot Global PCC or any of its related entities or their respective members or officers disclaim any responsibility for any errors or omissions in the information contained in this fact sheet including financial calculations. No representation or warranty, expressed or implied, is made as to the accuracy, completeness or thoroughness of the content of the information.