Equitable Investors has based its Soft Dollar standards on CFA Institute's Soft Dollar Standards. Essentially, these guidelines state that an Investment Manager "must always act for the benefit of its Clients and place Clients’ interests before its own".

For purposes of the Soft Dollar Standards, “soft dollar arrangements” include proprietary, as well as third-party, research arrangements.

In line with these standards, we make the following disclosures:

1. Equitable Investors has no soft dollar arrangements in place, however, it does receive research from a range of brokerage firms with whom it deals.

2. When that research is of value, Equitable Investors will consider the source of the research as a candidate for executing relevant trades. Equitable Investors primarily uses that research to benefit the clients paying brokerage related to these trades (primarily Equitable Investors Dragonfly Fund). However, it may also use such research to benefit clients other than those whose trades generated brokerage for the source of the research, such as managed account clients for whom execution occurs through Interactive Brokers. Such research may also benefit principal entities, although where possible they would be paying their share of execution costs.

3. The types of research Equitable Investors receives include traditional research reports and corporate access. Equitable Investors strives to undertake its own detailed research and reviews third party written research as a check or a prompt, rather than relying on third party recommendations. Equitable Investors pursues its own corporate access program as a core function but also values corporate access where it is facilitated by a third party.

Set out below are the CFA Institute Soft Dollar Standards as we have adopted them, with some minor amendments where the source text was USA-specific.

Soft Dollar Standards

I. General

Principles

A. These Soft Dollar Standards apply to all CFA Institute Members’ Proprietary and Third-Party Research Arrangements, with or without Commissions, and recognize two fundamental principles:

1. Brokerage is the property of the Client.

2. The Investment Manager has an ongoing duty to ensure the quality of transactions effected on behalf of its Client, including

a. seeking to obtain Best Execution,

b. minimising transaction costs, and

c. using Client Brokerage to benefit Clients.

Standards

B. An Investment Manager in Soft Dollar Arrangements must always act for the benefit of its Clients and place Clients’ interests before its own.

C. An Investment Manager may not allocate a Client’s Brokerage based on the amount of Client referrals the Investment Manager receives from a Broker. Clarification: With respect to mutual funds, the Investment Manager’s Client is the fund.

II. Relationships with Clients

Standards

A. The Investment Manager must disclose to the Client that it may engage in Soft Dollar Arrangements prior to engaging in such Arrangements involving that Client’s account.

B. The Investment Manager should assure that, over time, all Clients receive the benefits of Research purchased with Client Brokerage.

1. Agency Trades. While it is permissible for the Investment Manager to use a Client’s Brokerage derived from Agency Trades to obtain Research that may not directly benefit that particular Client at that particular time, the Investment Manager should endeavor to ensure that, over a reasonable period of time, the Client receives the benefit of Research purchased with other Clients’ Brokerage.

2. Principal Trades. The Investment Manager should determine if the particular Principal Trade is subject to certain fiduciary requirements which require that Client Brokerage derived from Principal Trades must benefit the Client account generating the Brokerage. If such requirements do not apply, it is permissible to use Client Brokerage derived from Principal Trades to benefit Client accounts other than the account generating the Brokerage if the Investment Manager discloses this practice and obtains prior consent from the Client.

Clarification: Compliance with the Soft Dollar Standards should not be read to, in any way, absolve one’s responsibilities to comply fully with the applicable law regarding Principal Trades.

III. Selection of Brokers

Principle

A. Selecting Brokers to execute Clients’ Securities Transactions is a key component of the Investment Manager’s ability to add value to its Client portfolios. The failure to obtain Best Execution may result in impaired performance for the Client. Required B. In selecting Brokers, the Investment Manager must consider the capabilities of the Broker to provide Best Execution.

Standards

B. In selecting Brokers, the Investment Manager must consider the capabilities of the Broker to provide Best Execution.

C. In evaluating the Broker’s capability to provide Best Execution, the Investment Manager should consider the Broker’s financial responsibility, the Broker’s responsiveness to the Investment Manager, the Commission rate or spread involved, and the range of services offered by the Broker.

Clarification: These criteria are relevant components to the Broker’s ability to obtain the most favorable total cost under the particular circumstances at that time.

IV. Evaluation of Research

Standards

A. In determining whether to use Client Brokerage to pay for Research, the Investment Manager must use the following criteria:

1. Whether the Research under consideration meets the definition of Research contained in these Standards.

2. Whether the Research benefits the Investment Manager’s Client(s).

3. Whether the Investment Manager is able to document the basis for the determinations.

4. Whether under certain fiduciary regulations for Principal Trades, the Research directly benefits the Client account generating the trade. If the Principal Trades are not subject to such regulations, the Research may benefit Client accounts other than those generating the trade if the Investment Manager has made disclosure and obtained prior Client consent.

B. The inability to decide and document that the Research meets the above criteria requires that the Investment Manager not pay for such Research with Client Brokerage.

C. In determining the portion of Mixed-Use Research to be paid with Client Brokerage, the Investment Manager must:

1. Be able to make a reasonable, justifiable, and documentable allocation of the cost of the Research according to its expected usage.

2. Pay with Client Brokerage only the portion of the Research that is actually used by the Investment Manager in the Investment Decision-Making Process.

3. Reevaluate the Mixed-Use Research allocation at least annually.

V. Client-Directed Brokerage

Principle

A. Because Brokerage is an asset of the Client, not the Investment Manager, the practice of Client-Directed Brokerage does not violate any investment manager duty per se.

Standards

B. In a Client-Directed Brokerage Arrangement:

1. The Investment Manager must not use Brokerage from another Client account to pay for a product or service purchased under the Client-Directed Brokerage Arrangement.

2. The Investment Manager should disclose to the Client:

a. the Investment Manager’s duty to continue to seek to obtain Best Execution, an

b. that arrangements that require the Investment Manager to commit a certain percentage of Brokerage may affect the Investment Manager’s ability to (i) seek to obtain Best Execution and (ii) obtain adequate Research.

VI. Disclosure

In addition to disclosure required elsewhere in the Soft Dollar Standards:

A. An Investment Manager must clearly disclose, with specificity and in “plain language,” its policies with respect to all Soft Dollar Arrangements, including:

1. To Clients and potential Clients. An Investment Manager must disclose whether it may use the Research to benefit Clients other than those whose trades generated the Brokerage. This disclosure must address whether the trades generating the Brokerage involved transactions conducted on a principal basis.

2. To Clients. An Investment Manager must disclose (i) the types of Research received through Proprietary or Third-Party Research Arrangements; (ii) the extent of use; and (iii) whether any affiliated Broker is involved.

Clarification: Description of the types and use of Research should be appropriate to the type of Research Arrangement involved. The disclosures required or recommended in the Soft Dollar Standards do not contemplate an “unbundling” of Proprietary Research Arrangements. Instead, the description of Research should, in the judgment of the Investment Manager, provide Clients with the ability to understand the type of Research involved in the degree of detail appropriate to the source of the Research.

B. To claim compliance with these Standards for any Client account, an Investment Manager must provide the Client with a statement that any Soft Dollar Arrangements with respect to the particular Client account comport with the CFA Institute Soft Dollar Standards. This statement must be provided at least annually.

Clarification: This statement is required only if the Investment Manager is claiming compliance with the Soft Dollar Standards. If applicable, the statement is to be provided to the individual Client to which the claim is being made.

C. An Investment Manager must prominently disclose in writing to its Client that additional information in accordance with the CFAInstitute Soft Dollar Standards concerning the Investment Manager’s Soft Dollar Arrangements is available on request. Such additional information should include the following on at least an annual basis:

Clarification: Although certain additional information is suggested, the Soft Dollar Standards are intended to preserve the ability of the Client and Investment Manager to determine what other information may be relevant in light of particular Client needs or types of accounts.

1. On a firmwide basis. A description of the products and services that were received from Brokers pursuant to a Soft Dollar Arrangement, regardless of whether the product or service derives from Proprietary or ThirdParty Research Arrangements, detailed by Broker.

2. For a specific Client account:

a. the total amount of Commissions generated for that Client through a Soft Dollar Arrangement, detailed by Broker; and

b. the total amount of Brokerage directed by that Client through Directed Brokerage Arrangements.

Clarification: The disclosure required in this section is intended to provide the requesting Client with certain basic items of information: a description of what the entire firm obtained through Soft Dollar Arrangements, the identity of brokers providing those products and services, the total amount of Directed Brokerage attributable to the Client, and the total amount of Commissions generated for the requesting Client’s account.

3. The aggregate percentage of the Investment Manager’s Brokerage derived from Client-Directed Brokerage Arrangements and the amount of that Client’s Directed Brokerage, as a percentage of that aggregate.

a. The Investment Manager is not obligated to report amounts of Client-Directed Brokerage that constitute less than 10 percent of the Manager’s aggregate amount of Client-Directed Brokerage.

When requested by a Client:

D. The Investment Manager should provide a description of the product or service obtained through Brokerage generated from the Client’s account.

E. The Investment Manager should provide the aggregate dollar amount of Brokerage paid from all accounts over which the Manager has Investment Discretion.

VII. Record Keeping

The Investment Manager must maintain, when applicable, all records that

A. are required by applicable law;

B. are necessary to supply Clients on a timely basis with the information required by Soft Dollar Standard VI;

C. document arrangements, oral or written, obligating the Investment Manager to generate a specific amount of Brokerage;

D. document arrangements with Clients pertaining to Soft Dollar or Client-Directed Brokerage Arrangements;

E. document any agreements with Brokers pertaining to Soft Dollar Arrangements;

F. document transactions with Brokers involving Soft Dollar Arrangements, including (1) a list of Proprietary or Third-Party Research providers and (2) a description of the service or product obtained from the provider;

G. document the bases of allocation in determining to use Client Brokerage to pay for any portion of a Mixed-Use service or product;

H. indicate how the services and products obtained through Soft Dollar Arrangements directly assist the Investment Manager in the Investment Decision-Making Process;

I. show compliance with the CFA Institute Soft Dollar Standards, including the identity of the Investment Manager personnel responsible for determining such compliance.

J. copies of all Client disclosures and authorizations.