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P 519 Alpha Group Capital Paul Barren Item 11. Code of Ethics, Participation or Interest In Client Transactions and Personal Trading Employees of Alkeon and their immediate family members may, from time to time, make investments for their own accounts that differ from the investments that Alkeon make
its the timing and execution of those trades so as not to disadvantage client positions. Trades of employees and family members will be monitored by Jennifer Shufro, Alkeon's Managing Director of Legal and Compliance (the "Compliance Director"). In addition, employees and related persons are required to have du
a Delaware limited liability company ("SilverBay") that was formed in August 2009, which is also registered as an investment adviser with the SEC. Alkeon's personnel (through SilverBay) manage ACAP Strategic Fund and Bluepoint Investment Series Trust, both registered investment companies, and may man
ervised persons' activities, including the investment advice that each provides to clients. Greg Jakubowsky (Alkeon's Chief Compliance Officer) and Jennifer Shufro (Alkeon's Managing Director of Legal and Compliance) supervise Alkeon's supervised persons by monitoring their compliance with Alkeon's Code of Eth
erage commissions which a client pays may vary in accordance with the particular broker used to execute a trade and the type of portfolio managed by Alkeon on behalf of a particular client. Rates for both listed and over-the-counter ("OTC") trades executed through electronic crossing networks ("ECNs")
e that brokers are selected on the basis of the brokerage and research services provided to Alkeon (all gifts in excess of $100 must be reported to Jennifer Shufro, Alkeon's Compliance Director). No Alkeon employee may solicit gifts, and no cash gifts may be accepted. Alkeon may also execute securities transac
a Delaware limited liability company ("SilverBay") that was formed in August 2009, which is also registered as an investment adviser with the SEC. Alkeon's personnel (through SilverBay) manage ACAP Strategic Fund and Bluepoint Investment Series Trust, both registered investment companies, and may man
ervised persons' activities, including the investment advice that each provides to clients. Greg Jakubowsky (Alkeon's Chief Compliance Officer) and Jennifer Shufro (Alkeon's Managing Director of Legal and Compliance) supervise Alkeon's supervised persons by monitoring their compliance with Alkeon's Code of Eth
Entities connected to both Alkeon and Jennifer Shufro
Paul Barren
PERSONSilverBay Capital Management
ORGANIZATIONSilverBay
ORGANIZATIONBreakwater
ORGANIZATIONGreg Jakubowsky
PERSONthe ACAP Strategic Fund
ORGANIZATION