Polar Capital LLP

ITEM 5 -- Fees and Compensation

       Polar Capital charges each Polar Fund, in the aggregate, a management fee (ranging
       between 0.375 and 1.5 percent annually) and a performance fee (see Item 6), as
       specifically described in each 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 a Polar Fund. 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 applicable fund.
       In addition redemption fees may be charged under certain circumstances, including
       transfers from one class of a fund’s shares to another class.

       The fees applicable to each Managed Account are set forth in detail in each Managed
       Account's investment management agreement.

       All fees for Managed Accounts are subject to negotiation and established pursuant to
       each Managed Account's investment management agreement. Generally, the
       investment management agreements are terminable upon receipt by either party from
       the other of prior written notice of termination and after the expiration of the specified
       notice period and the client will be entitled to any unearned prepaid portion of the
       Management Fee to the extent applicable.

       Fees are deducted from the assets of the relevant Polar Fund and typically computed on

Polar Capital LLP
Part 2A of Form ADV: Firm Brochure
       a regular basis by the administrator of the applicable Polar Fund, and paid to Polar
       Capital by the Polar Fund’s administrator as specified in the governing investment
       management agreement. Polar Capital cannot automatically deduct fees from client
       accounts, although the investment management agreement generally authorizes
       payment from the client account. Polar Funds also incur brokerage, custodial,
       administration, audit and other costs and expenses, as described in each Polar Fund’s
       prospectus.

       Employees of Polar Capital and its affiliates may invest in 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

       Polar Capital offers its services primarily to Polar Funds and managed accounts, all
       of which are pooled investment vehicles, as described in Item 4. Investors in 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 Capital and its affiliates invest in one or more of the Polar
       Funds. U.S. persons must be Qualified Purchasers or Accredited Investors in order
       to invest in Polar Funds. The 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 Polar Funds reserve
       the right to reject any investor application.

       Polar Capital also provides advisory and/or sub-advisory services to U.S. registered
       investment companies and U.S. private funds.

Polar Capital LLP
Part 2A of Form ADV: Firm Brochure