XTJA

The fund manager has adopted a policy pursuant to Rule 35d -1 under the 1940 Act to invest, under normal circumstances, at least 80% of its net assets (plus any borrowings for investment purposes) in investments that provide exposure to the SPDR ® S&P 500 ® ETF Trust (the “Underlying ETF”). The underlying ETF seeks to track the investment results of the S&P 500 Index, a large-cap, market-weighted, U.S. equities index that tracks the performance of 500 leading companies in leading industries. It is non-diversified.