UPPERQ HAS INCLUDED IN EXHIBIT 1 DETAILS ABOUT THE INTERNAL DISPER...

3. UpperQ has included in Exhibit 1 details about the internal dispersion of the portfolios in the

composite (comprising the data in the table and note 5) plus details about the external dispersion

of composite returns over time (note 6). Are these details compliant with GIPS?

Internal Dispersion

External Dispersion

A. Compliant

Compliant

B. Not compliant

Compliant

C. Compliant

Not compliant