19. Independence of the Trustee

The Trustee is not independent of the Fund Manager for the purposes of Article 18(b) if:

(a) the Fund Manager or the Trustee holds, or exercises voting rights in respect of, any shares of the other;
(b) the Fund Manager and the Trustee have a common holding company or a common ultimate holding company;
(c) the Fund Manager or the Trustee have directors on its Governing Body, who are also directors of the other;
(d) the Fund Manager or the Trustee has individuals performing Licensed Functions who are also individuals performing Licensed Functions for the other; or
(e) the Fund Manager and the Trustee have been involved in the previous 2 years in any professional or material business dealings, other than acting as Fund Manager or Trustee respectively of any other Fund.