Occasionally, Independence Square Holdings, LLC may have limited access to Initial Public Offering (IPO) shares.

Except with respect to the limited exception noted below, Independence Square generally does NOT purchase or recommend for purchase IPOs for its individual client accounts.

The limited exception to the above policy is:

1. For initial public offerings of large recognized company securities, and only to the extent that, Independence Square first determines such IPO is suitable for its clients; and the IPO is available through its existing clearing or custodial firm relationships.

2. For those individual clients of Independence Square who, on a completely unsolicited basis, contact Independence Square to request that we purchase a specific IPO for that client’s account, to the extent that the specific IPO has been made available to the firm.

In the event of any such unsolicited request, after first determining that the client is qualified for the specific IPO (i.e., it is suitable for the client relative to the client’s investment objectives, financial situation and current asset allocation), and to the extent possible under the circumstances, Independence Square may purchase the IPO on a pro-rata basis with other unsolicited client requests. To the extent applicable under the circumstances, Independence Square will use reasonable efforts to allocate available IPO shares on a fair and equitable basis in accordance with the terms and conditions of this policy.