POLICY OF INDEPENDENCE

All investment research issued by Vanda Research Ltd (“Vanda”) is independent, impartial and objective. Vanda does not conduct any investment business with or for its clients, other than the provision of investment research and advice, and the provision of data. Vanda staff have no other responsibilities which could conflict with the interests of our clients. Vanda does not carry out any corporate finance business; and has no involvement in raising capital for corporate clients. Vanda has no other regulated or unregulated business activities which conflict with its provision of independent research and data.

CONDUCT OF OUR INVESTMENT ANALYSTS

All of Vanda’s research analysts are supervised by appropriate senior members of the firm. In the event of any conflict of interest, Vanda requires all relevant employees to disregard any material interest or conflict of interest when advising a customer. Our analysts are not permitted to be involved in any activities which could be seen as conflicting with our provision of investment research to our clients. No inducements offered by issuers, or others with a material interest in the subject matter of investment research, may be accepted by our investment analysts or directors of the firm. No employee of Vanda may carry out any personal account dealing in a security in advance of its coverage in an upcoming note or immediately after the note’s coverage. In addition, a prohibited list of securities is maintained. All outside business activities of employees are subject to prior approval by a director of the firm.

OUR RESEARCH

Before being issued, all research documents must be approved and signed-off by an approved employee of Vanda. No one outside Vanda may comment on draft investment research before publication, other than, where necessary, to verify factual information. Certain disclaimers may be included in our research where appropriate, for example for legal reasons. Vanda’s policy and procedures require investment research to be distributed in an appropriate manner.

Our investment research is published and distributed electronically. No employee may communicate the substance of any investment research, except in accordance with our policy of independence.