Ruffer LLP

ITEM 5:	 FEES AND COMPENSATION                                  degree of responsibility assumed, complexity of the
                                                                engagement, special skills needed to solve problems,
We base our fees on a percentage of assets under
                                                                the application of experience and knowledge of the
management. Our fee schedules are described below.
                                                                client’s situation.
COMPENSATION – INVESTMENT                                       Our fees are exclusive of brokerage commissions,
MANAGEMENT SERVICES                                             transaction fees, and other related costs and expenses
Our annual investment management fees are                       which shall be incurred by the client. Such charges,
calculated upon the level of chargeable assets under            fees and commissions are exclusive of and in addition
management in accordance with a tiered fee scale. The           to our fees, and we shall not receive any portion of
applicable fee is noted in the IMA.                             these commissions, fees, and costs.

The asset-based fee is billed on a quarterly basis, in          Clients should note that similar management services
arrears, based upon the market value of the client’s            may (or may not) be available from other registered
account, on the last day of the previous quarter.               investment advisers for similar or lower fees.

It should be noted that in order to ensure there is no          ITEM 6:	 PERFORMANCE-BASED FEES AND
double charging to clients, holdings in any Ruffer funds
                                                                SIDE-BY-SIDE MANAGEMENT
are excluded from the calculation of the investment
management fees where Ruffer receives a management              ‘Performance-Based Fees’ are fees based on the capital
fee directly from the fund.                                     gains or capital appreciation in an account. We do not
                                                                charge performance-based fees.
There are normally no initial or termination charges
for new or leaving clients.                                     Fee arrangements vary by client as described in
                                                                Item 5. As a result, conflicts of interest could arise with
CALCULATION AND PAYMENT                                         respect to the allocation of more profitable trades to
The specific manner in which we charge fees is                  higher fee-paying accounts. To mitigate such potential
established in a client’s written agreement with us. The        conflicts of interest, the Firm’s policies and procedures
amount due in fees is debited directly from our client’s        state that investment decisions are to be made in
accounts unless they have elected to be invoiced                accordance with our fiduciary duties and regulatory
directly for fees.                                              principles. In determining the suitability of investment
                                                                opportunities for client accounts and funds, we
Accounts initiated during a calendar quarter will
                                                                consider several factors, including their investment
be charged a prorated fee. Upon termination of any
                                                                objectives, constraints, existing portfolio composition,
account, the fee for the final, partial calendar quarter
                                                                and legal or process constraints surrounding the
will be prorated. Any prepaid, unearned fees will be
                                                                investment. See Item 11 for additional information on
promptly refunded, and any earned, unpaid fees will be
                                                                conflicts management.
due and payable.

TYPES OF CLIENTS
                                                             Technical analysis does not consider the underlying
In the US, discretionary investment management               financial condition of a company. This presents
services are marketed to non-retail investors,               a risk in that a poorly managed or financially
including: banks or thrift institutions, pooled              unsound company may underperform regardless of
investment vehicles, pension and profit-sharing plans,       market movement.
trusts, estates and charitable organizations, family
                                                             The terms ‘charting’ and ‘technical’ analysis are
offices, corporations and other investment managers.
                                                             generally used synonymously and therefore, for
ACCOUNT MINIMUMS                                             the purpose of this document, we will use the term,
                                                             ‘technical analysis.’
For our separately managed accounts we require a
minimum size of $100,000,000. We may group certain           Cyclical analysis, which measures the movements of
related client accounts for the purposes of achieving        a particular stock against the overall market in an
the minimum account size.                                    attempt to predict the price movement of the security.

In exceptional circumstances, we have the discretion
                                                             INVESTMENT STRATEGIES
to waive the account minimum. Accounts of less than
                                                             We have one global, macro-driven, absolute return
$100,000,000 may be set up when we anticipate
                                                             strategy that is unchanged since our Firm began in
the client will add additional funds to the accounts
                                                             1994. We define this single investment strategy with
bringing the total to $100,000,000 within a
                                                             two simple investment objectives
reasonable time.
                                                             1	 not to lose money in any 12 month rolling period
The account minimums for funds are provided in the
respective fund offering documents.                          2	 to grow funds at a higher rate than would be
                                                                achieved by depositing them in cash