Anti-Money Laundering Policy

President Bush signed into law the Public Law No. 107-56, Money Laundering Abatement Act, (USA Patriot Act of 2001.) This law significantly impacts the financial services industry and providers of electronic communications services and grants law enforcement expanded investigative authority over Client information that may in certain circumstances supercede GLB and Reg. S-P restrictions.

According the NASD Notice to Members 02-21: Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origin of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets. Generally, all Certium Asset Management ("Certium") officers and employees are responsible for firm compliance with all anti-money laundering requirements.

Certium may, at any time, be required to obtain Client verification and certification of residency. This may include, but is not limited to, obtaining proof of tax identification, individual social security numbers, state or country of residency and birth, passport identification, bank account verifications, and other documentation as required by the federal government and/or other regulatory agencies. Certium is restricted from opening and/or maintaining accounts with/through/for shell banks and will immediately cease managing such accounts regardless of when the situation is discovered.

Please contact the Compliance Officer at Certium Asset Management LLC, 3333 Piedmont Road, NE, Suite 1500, Atlanta, GA 30305, or at (404) 845-7696 for further information, questions and/or concerns regarding Certium's Anti-Money Laundering Program.