(Articles 12 and 18 of Directive 2011/61/EU)

1. For any relevant person who is involved in activities that may give rise to a conflict of interest, or who has access to inside information within the meaning of Article 1(1) of Directive 2003/6/EC of the European Parliament and of the Council of 28 January 2003 on insider dealing and market manipulation (market abuse) [OJ L 96, 12.4.2003, p. 16.] or to other confidential information relating to an AIF or transactions with or for an AIF, an AIFM shall establish, implement and maintain adequate arrangements aimed at preventing such relevant persons from:

(a) entering into a personal transaction in financial instruments or other assets which fulfils one of the following criteria:

(i) the transaction is subject to Article 2(1) of Directive 2003/6/EC;

(ii) the transaction involves the misuse or improper disclosure of confidential information;

(iii) the transaction conflicts or is likely to conflict with an obligation of the AIFM under Directive 2011/61/EU;

(b) advising or inducing, other than in the proper course of his employment or contract for services, any other person to enter into a personal transaction referred to in point (a)(i) and (ii), or that would otherwise constitute a misuse of information relating to pending orders;