ARCHON PARTNERS LLC

Archon provides investment advisory services to pooled investment vehicles that rely on exemptions from registration under the Investment Company Act of 1940 and the Securities Act of 1933. Archon serves as the investment manager to a long/short equity private investment fund, Archon Partners L.P. Investment advice is provided directly to the Private Fund, subject to the discretion and control of the general partner or the board of directors of the Private Fund, and not individually to the limited partners or shareholders of the Client. Archon conducts quarterly reviews to evaluate best execution for its Client and adherence to policies and procedures. It also reviews its best execution policies at least annually. Archon assesses factors in selecting service providers and believes it has adopted an objective review process that mitigates conflicts of interest.

The Archon Partners Fund aims for long-term capital growth with flexible investment parameters, utilizing both long and short positions. It primarily invests in publicly traded, mid-cap and large-cap equities, but is not restricted by market capitalization, geographical area, or investment type, allowing for investments in corporate bonds and other instruments. The fund's investment philosophy centers on identifying companies or industries undergoing significant fundamental change, believing that positive change leads to above-average sales and earnings. Archon's portfolio managers conduct fundamental analysis, using in-house and outside research, to identify potential investments. They seek companies with large market opportunities, attractive competitive structures, rapid growth potential, high and improving returns on capital, and attractive prices relative to their prospects. They look for significant fundamental changes such as new management, groundbreaking products, corporate turnarounds, entry into new markets, altered regulatory environments, industry consolidation, and industries benefiting from demographic shifts.

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