Disclosures

Seabank Capital Management Inc. is an independent company owned by its employees and
does not have any related, connected or associated relationships which may impair its
independent status.

We adhere to a policy of full disclosure and have policies and procedures in place to address
areas of potential conflicts of interest.

When we purchase or sell securities on behalf of clients we seek "best execution".  Best
execution means that we place orders with broker/dealers based on a variety of factors
including lowest cost, best qualitative execution, value of research, execution capability
and responsiveness.

Our custodians provide us with a variety of services including trade execution, internal and
external research, portfolio management systems and investment management tools which
are used to the benefit of all clients.

Seabank Capital votes proxies on behalf of clients based on what we determine to be in the
best interest of our clients. Decisions incorporate what we believe are positive long-term
factors as they relate to the benefit of shareholder interests in conjunction with corporate
governance issues. Our proxy voting record is available for review upon request.

Important Disclosure Information

Seabank Capital Management, Inc. (“Seabank”) is an SEC registered investment adviser
in the United States and a Registered Portfolio Manager in Canada located in British Columbia,
Canada.  Seabank and its representatives are in compliance with the current filing requirements
imposed upon SEC/Canadian Provincial Securities Commissions registered investment
advisers by those states/provinces in which Seabank maintains clients. Seabank may only
transact business in those states/provinces in which it is registered, or qualifies for an
exemption or exclusion from registration requirements. Seabank’s web site is limited to the
dissemination of general information pertaining to its advisory services, together with
access to additional investment-related information, publications, and links.  Accordingly,
the publication of Seabank’s web site on the Internet should not be construed by any
consumer and/or prospective client as Seabank’s solicitation to effect, or attempt to effect
transactions in securities, or the rendering of personalized investment advice for
compensation, over the Internet.  Any subsequent, direct communication by Seabank with
a prospective client shall be conducted by a representative that is either registered or
qualifies for an exemption or exclusion from registration in the state/province where the
prospective client resides. For information pertaining to the registration status of Seabank,
please contact the SEC or the state/Canadian provincial securities regulators for those
states/provinces in which Seabank maintains a notice filing or registration.  A copy of
Seabank’s current written disclosure statement discussing Seabank’s business operations,
services, and fees is available from Seabank upon written request. Seabank does not
make any representations or warranties as to the accuracy, timeliness, suitability,
completeness, or relevance of any information prepared by any unaffiliated third
party, whether linked to Seabank’s web site or incorporated herein, and takes no
responsibility therefor.  All such information is provided solely for convenience
purposes only and all users thereof should be guided accordingly.

Please remember that different types of investments involve varying degrees of risk, and there
can be no assurance that the future performance of any specific investment or investment
strategy (including those undertaken or recommended by Seabank), will be profitable or
equal any historical performance level(s).

Certain portions of Seabank’s web site (i.e. newsletters, articles, commentaries, etc.) may
contain a discussion of, and/or provide access to, Seabank’s (and those of other investment
and non-investment professionals) positions and/or recommendations as of a specific prior
date.  Due to various factors, including changing market conditions, such discussion may no
longer be reflective of current position(s) and/or recommendation(s).  Moreover, no client or
prospective client should assume that any such discussion serves as the receipt of, or a
substitute for, personalized advice from Seabank, or from any other investment professional.
Seabank is neither an attorney nor an accountant, and no portion of the web site content
should be interpreted as legal, accounting or tax advice. 

Rankings and/or recognition by unaffiliated rating services and/or publications should not be
construed by a client or prospective client as a guarantee that he/she will experience a certain
level of results if Seabank is engaged, or continues to be engaged, to provide investment
advisory services, nor should it be construed as a current or past endorsement of Seabank by
any of its clients.  Rankings published by magazines, and others, generally base their selections
exclusively on information prepared and/or submitted by the recognized adviser.

Each client and prospective client agrees, as a condition precedent to his/her/its access
to Seabank’s web site, to release and hold harmless Seabank, its officers, directors, owners,
employees and agents from any and all adverse consequences resulting from any of
his/her/its actions and/or omissions which are independent of his/her/its receipt of
personalized individual advice from Seabank.