New Horizon Managers Limited

Item 5 – “Fees and Compensation – Payment of Fees.”

        Performance-based fee or allocation arrangements may create an incentive for us to
recommend investments that may be riskier or more speculative than those that we may
recommended under a different fee or allocation arrangement. In the allocation of investment
opportunities, performance-based fee or allocation arrangements may also create an incentive for
us to favor accounts with performance or incentive fee or allocation arrangements over accounts
that do not have such arrangements or, alternatively, favor accounts with higher performance-
based fee or allocation arrangements over accounts with lower performance-based fees or
allocation arrangements. We have adopted an investment allocation policy and procedures (the
“Allocation Policy”) designed to ensure that all of our clients are treated fairly and equitably and
to prevent this form of conflict from influencing the allocation of investment opportunities
among our clients. In accordance with our Allocation Policy, while each of our clients may not
participate in each individual investment opportunity on an overall basis, each client generally
will be entitled to participate equitably with our other clients.

        The Allocation Policy seeks to allocate investment opportunities among our clients in a
fair and equitable manner. Allocations of investment opportunities are not necessarily made on a
pro rata basis as our clients may pursue distinct investment strategies. Rather, we make
independent allocation decisions with respect to each client. Allocations of investment
opportunities among the clients are based on a variety of considerations, including potentially
different or conflicting investment objectives and strategies; the life cycle of various portfolios;
risk parameters (including, without limitation, the use of leverage); cash and liquidity availability
(e.g., allocation size may vary depending on a client’s cash availability, the other liquidity
obligations of the applicable client or commitments made to other investments); investment time
frames; and legal, tax, and regulatory considerations.

TYPES OF CLIENTS

         We currently provide investment advisory services to the Funds, which are offered to
institutional investors, including trusts, estates, charitable organizations, pension and profit
sharing plans; and commingled investment vehicles; high net worth individuals; and financially
sophisticated individuals.

       The minimum initial subscription for an investor in the Funds generally is $5,000,000.
Investors in the Funds must meet certain prescribed qualification criteria, including, being an
“accredited investor,” as defined in Rule 501(a) of Regulation D, promulgated pursuant to
Section 4(a)(2) of the U.S. Securities Act of 1933, as amended (the “Securities Act”). Such
minimum investment amounts and investor criteria are set forth in the offering documents of
each Fund.

       We may, in our sole discretion, waive any of these minimum account requirements.