The Chief Compliance Officer will be responsible for establishing, implementing, monitoring and enforcing all of Nuance’s policies and procedures regarding insider trading. If any supervised person is unsure whether information could violate Nuance’s policies and procedures on insider trading or has questions on any aspect of Nuance’s policies and procedures on insider trading, questions should be directed to the Chief Compliance Officer prior to implementing any trades. The prohibition on the use of inside information extends to family members, associates and acquaintances of the person coming into possession of such information.

The Chief Compliance Officer is responsible for establishing procedures, reviewing procedures, updating procedures and ensuring that all supervised persons are continuously aware of and understand procedures regarding insider trading policies and procedures. Nuance’s policies will be reviewed on a regular basis and updated as necessary. All supervised persons will be required to review Nuance’s written Compliance Manual at least annually. Supervised persons will then sign an acknowledgement indicating that they are aware of, understand and agree to comply with Nuance’s policies and procedures at all times. Since Nuance’s insider trading policies and procedures are included in this manual, supervised persons are acknowledging that they are aware of, understand and will comply with Nuance’s insider trading policies and procedures at all times. If Nuance is aware of any securities that it is restricted from trading, the Chief Compliance Officer will maintain a list of these securities. This list will be kept current at all times and will be provided to all supervised persons on a regular basis.