Polar Capital America Corporation

ITEM 5 -- Fees and Compensation

            Each Served Polar Fund pays Polar America and Polar Capital, in the aggregate, a
            management fee of up to two percent annually and a performance fee (see Item 6), as
            specifically described in the Served Polar Fund’s prospectus. An initial fee of up to 5
            percent of the subscribed amount may be payable by subscribers of New Participating
            Shares in the Served Polar Funds. The initial fee will be payable to the extent that the
            fees and expenses of intermediaries need to be met, if not waived by the directors of the
            Served Polar Funds. In addition, redemption fees may be charged under certain
            circumstances, including transfers from one class of the Served Polar Fund’s shares to
            another class.

            Fees are deducted from the assets of the relevant Served Polar Funds and are typically
            computed on a regular basis by the administrator of the Served Polar Funds, and paid to
            Polar America as specified in the governing investment management agreement. Polar
            America cannot automatically deduct fees from client accounts, although the investment
            management agreement generally authorizes payment from the client account. The
            Served Polar Funds also incurs brokerage, custodial, administration, audit and other costs
            and expenses, as described in its prospectus.

            Employees of Polar America and its affiliates may invest in the Served Polar Funds and
            in other Polar Funds, and in the case of portfolio managers and analysts, are encouraged
            to invest in the funds they manage.

ITEM 7 -- Types of Clients

            As sub-adviser to Polar Capital, Polar America provides its services to the Served Polar
            Funds, which are a pooled investment vehicles, as described above in Item 4. Investors
            in the Served Polar Funds include individuals, banking or thrift institutions, investment
            companies (including mutual funds), pension and profit-sharing plans, pooled investment
            vehicles (such as hedge funds), high net worth individuals, collateralized debt obligations
            (CDO’s), charitable organizations, trusts and estates, corporations and other business
            entities, and state or municipal government entities. Certain employees of Polar America
            and its affiliates invest in the Served Polar Funds. U.S. persons must be Qualified
            Purchasers in order to invest in the Served Polar Funds. The Served Polar Funds require
            investors to make representations concerning investors’ eligibility, sophistication,
            awareness of the inherent risks and ability to bear the risk of loss of their entire
            investment. The Served Polar Funds reserve the right to reject any investor application.