MANY INVESTORS IN THE FUND WERE NOT AWARE OF THE LEVEL OF LEVERAGE...

5. Many investors in the fund were not aware of the level of leverage being

employed by the fund both implicitly through the use of derivatives and

explicitly through borrowed funds.

Biggles goes on to evaluate the current Code of Ethics employed by Epic. She begins by

reviewing two of the firm’s compliance procedures, shown in Exhibit 2 below:

Exhibit 2

Epic Advisers Code of Ethics

Risk Management Process:

Managers are directly responsible for understanding and managing the risks inherent

in the funds that they run. The company is not deemed to be of a large enough size to

warrant a separate risk management function.

Record Keeping:

Records substantiating investment activity, research, policies and procedures, as well

as records of any violations and actions taken must be kept in electronic form at least

five years, as required by local regulation.