Selling Portfolio Securities

The Adviser's process for selling portfolio securities is based on a method that indicates a company has achieved the valuation target identified as appropriate, based on a variety of possible quantitative measures, to that particular issuer's securities. The valuation target identified for a given security may change if new data becomes available justifying a higher or lower target using the same valuation methodology applied in making the initial purchase decision for that security.

In addition, the Adviser monitors investment selections and will typically reevaluate investments that reflect, in its view, a shift in the issuer's fundamental outlook. Although the Adviser does not employ a strategy that requires selling an investment for the sole reason that the investment's value has fallen below a minimum threshold relative to such investment's purchase price, a decline in value of 10% or more will trigger the Investment Team to initiate a review process comprised of Steps Two and Three in the Adviser's process for purchasing securities. In determining which of these stocks to sell, the Adviser may consider such factors as information derived from discussions with the issuer's management and the security movements of competitors, as well as other relevant factors. Depending upon conditions prompting reevaluation of the Fund's position in a particular portfolio security, the Adviser's reevaluation process may result in a determination by the Investment Team to hold or add to the Fund's position, or, conversely, to sell the Fund's position in the portfolio security in question.