VENATOR MANAGEMENT LLC

Venator adheres to an opportunistic, value-oriented discipline regarding the management of all its client accounts. Venator believes independent thought, price discipline and rigorous risk- reward analysis are essential components of investment success. The investment advisory services provided to all clients include portfolio management, investment research, trading, proxy voting and client service. Venator’s clients grant Venator limited power of attorney providing Venator the authority to buy, sell or otherwise affect security transactions in the client’s name, at Venator’s discretion and without prior consultation with the client. Venator will actively manage client accounts only on a discretionary basis.

Venator employs different investment strategies for its Hedge Fund and separately managed accounts. The Hedge Fund strategy is both long-term and short-term oriented, with an ideal long portfolio consisting of 8 to 15 public or private securities positions. While there is no ideal short portfolio, smaller position sizes are favored for risk management. The Hedge Fund's portfolio may be substantially net long or net short depending on market conditions. For separately managed accounts, Venator uses the Multi Cap Value Strategy, an opportunistic and value-oriented approach that is not oriented towards a particular market capitalization. Investments may include micro, small, mid, and large cap public securities. The strategy is long-term oriented, with a typical long portfolio holding 10 to 20 public securities positions, concentrated in what Venator believes to be the best ideas.

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