This website is intended for general information purposes. Any opinions on investment products contained herein are not intended to convey any guarantees as to the future investment performance of these products. Under no circumstances should any material at this site be used or considered as an offer to sell or a solicitation of any offer to buy an interest in any security or investment managed by Langley Advisors Limited or its affiliates or any other product or service to any person in any jurisdiction, nor should it serve as the basis for any investment decision. In addition to the information herein contained, one investor considering the products and services analysed should carry out his own due diligence, should carefully study the account forms, disclosure documents and/or risk disclosure statements which are provided directly by the asset management companies, banking or brokerage counterparties. Past performance is no indication of future performance, and nothing on this Site should be interpreted to state or imply otherwise. The value of investments may fall as well as rise and investors may not get back the full amount invested. This website may contain information that has been obtained from other sources. Langley Advisors Limited gives no representations or warranties as to the accuracy of such information, and accepts no responsibility or liability (including for indirect, consequential or incidental damages) for any error, omission or inaccuracy in such information. In this website you may find addresses or hyperlinks leading out of this Website. The existence of any such links shall not constitute an endorsement, representation or warranty of such link. Users are advised that information on hyperlinked or referred-to websites is neither investigated nor analysed by Langley Advisors Limited. No warranty or representation, express or implied, is given as to the accuracy or completeness of such information. Langley Advisors Limited reserves the right to change the terms, conditions, and notices under which this site is offered. Opening this website shall not render the user a customer of Langley Advisors Limited nor shall Langley Advisors Limited owe such users any duties or responsibilities as a result thereof. The Terms and Conditions of this website are without prejudice to any contractual terms you may enter into with us, which will take precedence over the Terms and Conditions of this website. Any use of this website shall be subject to UK law.

Information on the investment firm and its services. LANGLEY ADVISORS LIMITED Investment management and advisory firm with registered office in 38b Lancaster Mews, London W2 3QF, United Kingdom, registered under 09820640. Langley Advisors Limited is authorized to provide financial services by the Financial Conduct Authority and is registered under 935676. Regulatory permissions: Advising (excluding pension transfers/opt-outs) Arranging (bringing about) deals in investments Making arrangements with a view to transactions in investments Dealing in investment as agent Managing Investments Investment types: Shares Government and Public Securities Warrants Certificates representing certain securities Units Options Options (including commodity option) Futures Futures (including commodity futures) Contracts for difference Rolling Spot Forex Rights to or interests in investments (contractually based investments) Rights to or interests in investments (security) Method of communication between the customer and the company Any communications between the Company and the customer, to receive information and documentation, as required by the Intermediaries Regulation, may take place in English or Italian and mainly by e-mail at the addresses and addresses indicated above, or by ordinary mail, by telephone on customer request.

First try to contact us directly. In most circumstances, we must reply within 8 weeks, or 15 days for payment services such as bank deposits, direct debits or online payments. If you are concerned you have been scammed, contact FCA Contact Centre https://fca.org.uk/contact and Action Fraud https://www.actionfraud.police.uk/ immediately. Complain to the firm: 38b Lancaster Mews, London W2 3QF, United Kingdom +447470071004 complaints@langleyadvisors.co.uk Report to the FCA: If you have concerns about a firm listed on the Register, contact the FCA directly https://www.fca.org.uk/contact. The Financial Ombudsman Service (FOS) may be able to consider a dispute with us. The Financial Services Compensation Scheme (FSCS) may be able to consider a claim against this firm if it fails.

I. SCOPE AND PURPOSE 1.0 What is the purpose of this Policy? This Policy provides general information in respect to Langley Advisors Limited’s (“Langley”) approach to Best Execution. This Best Execution Policy summarises the general basis in which Langley will provide best execution when required by the European Union’s Markets in Financial Instruments Directive 2 (known as “MiFID 2”) and by the rules, guidance, principles and codes in the handbook of Rules and Guidance issues by the UK Financial Conduct Authority or any successor regulatory body or bodies (the “FCA”). This Policy is also linked to the firm’s order execution policy, the requirement for which is documented in COBS 11.2A.20. 2.0 When does the policy apply? Clients In adherence with regulatory requirements, we classify clients as Professional Clients or Eligible Counterparties. Different levels of investor protection and product offering apply to each client category and clients can in certain circumstances choose to change classification. The obligation to provide Best Execution is applicable to clients categorised as Professional Clients – both “per se" and "elective" Professionals - of the firm. Clients categorised as Eligible Counterparties are commonly excused from the Best Execution obligation. Products This Policy applies to the following classes of financial instruments: Equities, Derivatives (both Exchange-traded and OTC), Units/Shares in Collective Investment Schemes, Fixed Income Instruments, Money market and cash instruments, as well as any other financial instruments in which we may execute orders from time to time. Furthermore, we are aware that there will be key differences in market structures and it may be difficult to identify and apply a uniform standard that will be effective for all financial instruments. Therefore, we will consider all circumstances surrounding the execution of orders for particular types of financial instrument. II. ACHIEVING BEST EXECUTION POLICY 3.0 What does Best Execution mean? “Best Execution” means that Langley must take all sufficient steps to obtain, when executing orders, the best possible results for clients, taking into account the execution factors. This includes directly executing transactions on behalf of the client on one or more execution venues or transmitting client orders to third parties for execution. Langley will be committed to complying with this policy and will take steps to monitor, review and update the policy to ensure that it continues to achieve such results. 4.0 What factors do we take into consideration? In order to achieve the best results, Langley will use the following factors; i) Price – The price the transaction in the financial instrument is executed at. ii) Costs – Costs that surround the possible market impact or external costs. For example, exchange or clearing fees. Other costs may include internal costs such as remuneration through commission or spread. iii) Speed – The time it takes to execute a client transaction including settlement. iv) Likelihood of execution and settlement - The likelihood that we will be able to complete a client transaction. v) Size - The size of the transaction executed for the client, and how this will affect the price of execution. vi) Nature - This is how the characteristics of a client transaction can affect how Best Execution is received. While total consideration (price and costs) are generally key factors, the overall value to you of a particular transaction may be affected by the other factors listed above. We may conclude that factors other than price and costs are more important in achieving the best possible result for you. The relative importance of each of the factors will differ depending on: your categorisation as Professional Client; any special objectives you may have in relation to the execution of the order; the characteristics of your order; the characteristics of the financial instruments to which your order relates; and the characteristics of the venues (if there is more than one) to which your order may be directed. We are required to provide an account of the relative importance of the execution factors, with reference to the relevant criteria (see above) and the process by which the firm determines the relative importance of those factors. This is outlined below in the Reporting and Ongoing monitoring section of this policy. 5.0 Order management and aggregation Where practical, Langley will look to aggregate purchase or sell orders for the same security or other instrument for multiple accounts so that the clients may be able to benefit from the better prices achieved through larger, bulk transactions in line with our obligation to treat customers fairly. Langley aggregates orders when it considers doing so appropriate and in the interest of its clients generally. Although it may do so in certain circumstances, Langley does not always aggregate orders for different accounts, if the portfolio management decisions relating to the orders are made for accounts with different investment strategies or risk profile. If aggregating is not appropriate or practicable from Langley’s operational or other perspective or if doing so would not be appropriate in light of applicable regulatory considerations, the executed orders will nonetheless be allocated to clients fairly and proportionately. III. COMPLIANCE WITH CLIENT INSTRUCTIONS 6.0 What happens if you give us specific instructions on how to execute your order? Any client specific instructions in relation to an order (eg. where the client places a ‘limit’ on the price for execution) will be followed so far as reasonably possible however the firm’s policy of best execution and obtaining the best possible result will not apply in relation to the part or aspect of the order to which the instructions relate but the policy may still apply to other aspects of the order to the extent that it is not covered by the clients instructions as per COBS 11.2A.25(66)(3f) IV. EXECUTING VENUES 7.0 How do we deliver best execution where there are competing execution venues? An execution venue is the term used to describe a place where a client order is executed and includes Regulated Markets, Multi-lateral Trading Facilities (MTF), Organised Trading Facilities (OTF) Systematic Internalisers (SI) and market makers or any other liquidity providers. Langley will in all instances transmit client orders, or place client orders with, a broker for execution. The broker will choose the execution venue used for a particular trade. Langley has a process for the selection of brokers, with whom it executes client orders or transmits client orders to for execution. 8.0 Broker Approval Process Langley currently employs Interactive Brokers (UK) Ltd as its primary broker. In choosing which broker to use, Langley will take into consideration the following factors relating to that broker: Access to alternative markets and trading venues; Adequate coverage to asset classes globally Commission rates and prices/spreads provided; Execution speed/latency; Quality of execution and service, both historical and current; Clearing and settlement efficiency and capabilities; Risk profile and creditworthiness; and Regulatory status and reputation Langley has a process for the selection of brokers, with whom it executes client orders or transmits client orders to for execution. All brokers are reviewed/assessed on an on-going basis against the mentioned above factors in accordance with our obligation to provide the client with the best possible execution results on a consistent basis. We undertake an annual review of appropriate brokers. This includes assessments of execution quality, service delivery, regulatory status and the financial standing of the firm. A list of all Brokers that we review for execution is available on request, however, we reserve the right to change the Brokers we use from time to time, as we deem appropriate subject to our internal authorisation process and this Policy. In order to minimise the risk of potential conflicts of interests, Langley does not receive any form of remuneration, discount or non-monetary benefit for directing orders to a particular venue or broker for execution. The selection of a broker for an order is driven solely by the factors and inputs as described in this Policy. In accordance with COBS 11.2A.36, Langley may select a single entity for execution where it is able to show that this provides the best possible result for its clients on a consistent basis and where it can reasonably expect that the selected entity will enable the firm to obtain results for clients that are at least as good as the results that could reasonably be expected from using alternative entities for execution. In doing so Langley’s assessment shall be supported by relevant data published by the entity with regards to; its execution quality, the execution venues the entity in itself uses; alongside internal analysis conducted by Langley in relation to its Broker approval process. Langley may execute all or part of a client order outside of a Trading Venue. We will therefore contact the client and await confirmation from the client to execute such orders in this manner. Unless the client clearly instructs otherwise, the client has been and will be treated as having provided explicit consent to trade OTC. This is linked to the firm’s order execution policy. V. REPORTS AND ONGOING MONITORING 9.0 How will we be publishing information on execution quality? In accordance with COBS 11.2A.34EU 65(6) , Langley is now obliged to report and publish the top five trading venues used on an annual basis. The reports will be made available on the company website and they will include the following; An Annual Top 5 Execution Venue Report class of financial instruments; venue name and identifier; volume of client orders executed on that execution venue expressed as a percentage of total executed volume; number of client orders executed on that execution venue expressed as a percentage of total executed orders; percentage of the executed orders referred to above that were passive and aggressive orders; percentage of orders referred to above that were directed orders; confirmation of whether the venue has executed an average of less than one trade per business day in the previous year in that class of financial instruments. An Annual Report About the Monitoring of the Execution Quality of all Used Execution Venues an explanation of the relative importance the firm gave to the execution factors of price, costs, speed, likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution; a description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders; a description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received; an explanation of the factors that led to a change in the list of execution venues listed in the firm's execution policy, if such a change occurred; an explanation of how order execution differs according to client categorisation, where the firm treats categories of clients differently and where it may affect the order execution arrangements; an explanation of whether other criteria were given precedence over immediate price and cost when executing retail client orders and how these other criteria were instrumental in delivering the best possible result in terms of the total consideration to the client; an explanation of how the investment firm has used any data or tools relating to the quality of execution VI. UPDATING THE POLICY AND QUESTIONS 10.0 How often will we update the Policy? We will update the Policy periodically as and when appropriate following a review every 6 months. An up to date version of the policy and a response to any related questions may be obtained at any time by contacting your account representative or via the website www.langleyadvisors.co.uk.

Privacy Policy Langley Advisors Limited treats the privacy of its investors and potential investors very seriously and we are registered under the UK Data Protection Act. This privacy policy sets out the basis on which any personal data we collect from you will be processed by us. Please note that this privacy policy only applies to this website, so when you link to other websites you should read the privacy policies for those websites. We are not responsible for the privacy policy or practices of third party websites. Information we may collect from you Website usage information which is collected using cookies (see below our section on cookies). We may keep a record of correspondence with you and we may use tracking technology on any emails which we send to you. Although this policy tells you about types of data we collect from you and how these are used, at the point at which you provide us with any information about you, we will ask for your consent to use that information. Cookies A "cookie" is a small piece of encoded information sent by a web server to be stored on your web browser (Internet Explorer, Firefox) so that it can remember something about you. The cookie stored on your web browser does not contain any personal information. Our system will issue cookies when you visit our website. If you do not wish to have a cookie stored on your computer, you should disable them in your browser’s security options.