In the event of a Promotion of a Fund by Direct Communication with a Client by any means, the Fund Manager shall abide by the following controls: 1. The recipient shall be a Client of the Fund Manager and shall expect to receive this kind of Financial Promotion. 2. Ensure that the caller on his behalf shall take in to account: a. Disclosure of information in a clear, fair, and a non-misleading manner b. Not to provide false, misleading or deceptive statement or apply inappropriate methods. c. Clarify the purpose of the Financial Promotion of the Fund at the beginning of the call; and identify himself and the Fund Manager he represents.