Santander Asset Management Sa SGIIC

Item 5 – Fees and Compensation

      SAM offers investment advisory services for a percentage of assets under
 management, subscription fees or performance-based fees.

        All fees are subject to negotiation.

         The specific manner in which fees are charged by SAM is established in a client’s
 written agreement with SAM. SAM will generally bill its fees on a quarterly or monthly
 basis, depending on the client’s needs. Clients may elect to be billed in advance or arrears
 each calendar quarter. Clients may also elect to be billed directly for fees or to authorize
 SAM to directly debit fees from client accounts. Management fees shall be prorated for
 each capital contribution and withdrawal made during the applicable calendar quarter
 (with the exception of de minimis contributions and withdrawals). Accounts initiated or
 terminated during a calendar quarter will be charged a prorated fee. Upon termination
 of any account, any prepaid, unearned fees will be promptly refunded, and any earned,
 unpaid fees will be due and payable.

 SAM’s fees are exclusive of brokerage commissions, transaction fees, and other related
 costs and expenses which shall be incurred by the client. Clients may incur certain
 charges imposed by custodians, brokers, third party investment and other third parties
 such as fees charged by managers, custodial fees, deferred sales charges, odd-lot
 differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and

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 taxes on brokerage accounts and securities transactions. Mutual funds and exchange
 traded funds also charge internal management fees, which are disclosed in a fund’s
 prospectus. Such charges, fees and commissions are exclusive of and in addition to SAM’s
 fee, and SAM shall not receive any portion of these commissions, fees, and costs.

 Item 12 further describes the factors that SAM considers in selecting or recommending
 broker-dealers for client transactions and determining the reasonableness of their
 compensation (e.g., commissions).

Item 7 – Types of Clients

 SAM provides portfolio advisory services to institutional investors and non-U.S. domiciled
 pooled investment vehicles.

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