Since Investment Portfolios allow direct access to Clients’ accounts and due to the confidentiality and privacy of the same, in addition to direct dealing in Securities sale and purchase orders systems, certain controls and internal audit restrictions that shall be applied by the Licensed Person, including the following: 1. The physical location at which Investment Portfolios are managed shall be secured and equipped with effective monitoring tools. 2. Access to such location shall be restricted to a limited number of employees who each shall be certified by the executive management of the Licensed Person, and that these employees shall be the only ones who are authorized to deal with the Clients’ accounts. 3. Complete separation shall be maintained between makers of investment decisions for Investment Portfolios managed by the Licensed Person and any person who executes orders for Investment Portfolios managed by the Licensed Person. 4. In the event of death or inheritance, and until a determination of the heirs is issued, the Licensed Person shall freeze the Client’s account unless otherwise the portfolio management contract specifies otherwise. Thus, when the Licensed Person obtains a copy of the determination of the heirs, he may remove the restrictions on the Client’s account and formal procedures to transfer the contents of the Client’s account to the heirs shall commence no later than three months. The Client’s account shall be finally closed after disbursements are completed.