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An Independent & Unbiased Approach to Investing

FLEETWOOD ASSET MANAGEMENT LTD.

Investment Advisory Services

TERMS OF USE


PLEASE READ THROUGH THESE TERMS OF USE CAREFULLY.


By using this Web site (this “Web Site”) you are deemed to have entered into an

agreement (this “Agreement”) with Fleetwood Asset Management Ltd. to be bound

by the terms set forth below. Fleetwood Asset Management Ltd. reserves the right,

at its sole discretion, to revise, modify, add or delete portions of these terms at any

time. Notification of changes in this Agreement will be posted on the Web Site.


TRANSMISSION OF THE INFORMATION CONTAINED HEREIN IS NOT INTENDED TO

CREATE AND RECEIPT DOES NOT CONSTITUTE A CLIENT RELATIONSHIP WITH

FLEETWOOD ASSET MANAGEMENT LTD. ANY OPINIONS EXPRESSED IN THIS SITE

ARE SUBJECT TO CHANGE WITHOUT NOTICE AND FLEETWOOD ASSET

MANAGEMENT LTD. IS NOT UNDER ANY OBLIGATION TO UPDATE OR KEEP CURRENT

THE INFORMATION CONTAINED HEREIN. FLEETWOOD ASSET MANAGEMENT LTD.

ACCEPTS NO LIABILITY WHATSOEVER FOR ANY LOSS OR DAMAGE OF ANY KIND

ARISING OUT OF THE USE OF ALL OR ANY PART OF THIS MATERIAL.



NOT FINANCIAL ADVICE


The material on this Web Site has no regard to the specific investment objectives,

financial situation, or particular needs of any visitor. It is published solely for

informational purposes and is not to be construed as a solicitation nor does it

constitute advice, investment or otherwise. References made to third parties are

based on information obtained from sources believed to be reliable but are not

guaranteed as being accurate. Visitors should not regard it as a substitute for the

exercise of their own judgment. Our comments are an expression of opinion. While

we believe our statements to be true, they always depend on the reliability of our

own credible sources. We recommend that you consult with a licensed, qualified

investment advisor before making any investment decisions.



USE OF PROPRIETARY INFORMATION


The Web Site is protected by copyright as a collective work and/or compilation,

pursuant to U.S. copyright laws, international conventions, and other copyright laws.

The contents of the Web Site are only for your personal, non-commercial use. All

materials contained on the Web Site are protected by copyright, and are owned or

controlled by Fleetwood Asset Management Ltd. or the party credited as the provider

of the content. You will abide by any and all additional copyright notices, information,

or restrictions contained in any content on the Web Site. You may download and

make one (1) copy of the content and other downloadable items displayed on this

Web Site for personal, noncommercial use only, provided that you maintain all

copyright and other notices contained in such content. Copying or storing of any

content for other than personal, noncommercial use is expressly prohibited without

the prior written permission from Fleetwood Asset Management Ltd. or the copyright

holder identified in the individual contents copyright notice.



NO WARRANTY OR GUARANTEE IMPLIED


THE INFORMATION AVAILABLE IN THIS WEB SITE IS PROVIDED “AS IS” AND

WITHOUT WARRANTIES OF ANY KIND EITHER EXPRESS OR IMPLIED. TO THE

FULLEST EXTENT PERMISSIBLE BY LAW, FLEETWOOD ASSET MANAGEMENT LTD.

MAKES NO REPRESENTATION OR WARRANTIES OF ANY KIND WHATSOEVER FOR

THE CONTENT ON THE WEB SITE OR THE MATERIALS, INFORMATION AND

FUNCTIONS MADE ACCESSIBLE BY THE SOFTWARE USED ON OR ACCESSED

THROUGH THIS WEB SITE, FOR ANY PRODUCTS OR SERVICES OR HYPERTEXT

LINKS TO THIRD PARTIES OR FOR ANY BREACH OF SECURITY ASSOCIATED WITH

THE TRANSMISSION OF SENSITIVE INFORMATION THROUGH THIS WEB SITE OR

ANY LINKED SITE. FURTHER, FLEETWOOD ASSET MANAGEMENT LTD. DISCLAIMS

ANY EXPRESS OR IMPLIED WARRANTIES, INCLUDING, WITHOUT LIMITATION,

NONINFRINGEMENT, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE.

FLEETWOOD ASSET MANAGEMENT LTD. DOES NOT WARRANT THAT THE FUNCTIONS

CONTAINED IN THIS WEB SITE OR ANY MATERIALS OR CONTENT CONTAINED

THEREIN WILL BE UNINTERRUPTED OR ERROR FREE, THAT DEFECTS WILL BE

CORRECTED, OR THAT THIS WEB SITE OR THE SERVER THAT MAKES IT AVAILABLE

IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. FLEETWOOD ASSET

MANAGEMENT LTD. DOES NOT WARRANT OR MAKE ANY REPRESENTATION

REGARDING THE USE OR THE RESULTS OF THE USE OF THE INFORMATION IN THIS

WEB SITE.



LIMITATION OF LIABILITY


IN NO EVENT WILL FLEETWOOD ASSET MANAGEMENT LTD., ITS MEMBERS,

OFFICERS, EMPLOYEES OR THEIR AFFILIATES BE LIABLE FOR INDIRECT, DIRECT,

SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES (INCLUDING, WITHOUT

LIMITATION, DAMAGES FOR LOSS OF BUSINESS PROFITS, BUSINESS

INTERRUPTION, LOSS OF BUSINESS INFORMATION, PAIN AND SUFFERING,

EMOTIONAL DISTRESS THAT RESULT FROM THE USE OF, OR THE INABILITY TO

USE, THE MATERIALS IN THIS WEB SITE, OR OTHER PECUNIARY LOSS) ARISING

DIRECTLY OR INDIRECTLY FROM THE USE OF (OR FAILURE TO USE) OR RELIANCE

ON THE INFORMATION CONTAINED WITHIN, OR AS A RESULT OF THE RISKS

INHERENT IN THE STOCK MARKET, EVEN IF FLEETWOOD ASSET MANAGEMENT LTD.

HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.



INDEMNIFICATION


You agree to defend, indemnify and hold Fleetwood Asset Management Ltd., its

shareholders, officers, employees and their affiliates harmless from and against any

and all claims, losses, liability costs and expenses (including but not limited to

attorneys’ fees) arising from your violation of this Agreement, state or federal

securities laws or regulations, or any third party’s rights, including but not limited to

infringement of any copyright, violation of any proprietary right and invasion of any

privacy rights. You shall cooperate as fully as reasonably required in the defense of

any claim. Fleetwood Asset Management Ltd. reserves the right, at its own expense,

to assume the exclusive defense and control of any matter otherwise subject to

indemnification by you and you shall not in any event settle any matter without the

written consent of Fleetwood Asset Management Ltd.. This obligation will survive the

termination of this Agreement.



IMPORTANT CONSUMER INFORMATION


1. An investment advisor or investment advisor representative may only

transact business in a particular state after licensure or satisfying

qualifications, requirements of that state, or only if they are excluded or

exempted from the state's investment advisor or investment advisor

representative requirements, as the case may be.


2. Follow-up, individualized responses to consumers in a particular state by an

investment adviser or investment advisor representative that involve either

the effecting or attempting to effect transactions in securities or the rendering

of personalized investment advice for compensation, as the case may be,

shall not be made without first complying with the state's investment advisor,

or investment advisor representative requirements, or pursuant to an

applicable state exemption or exclusion.


3. For information concerning the licensure status or disciplinary history of an

investment advisor or investment advisor representative, a consumer should

contact his or her state securities law administrator.



CONFIDENTIALITY


You acknowledge that transmission to and from this Web Site are not confidential

and your communications may be read or intercepted by others. Persons contacting

Fleetwood Asset Management Ltd. through this Web Site should not send sensitive,

privileged, or confidential information. You acknowledge that by submitting

communications to Fleetwood Asset Management Ltd., no confidential, fiduciary,

contractual or other relationship is created between you and Fleetwood Asset

Management Ltd. other than pursuant to this Agreement.



ENTIRE AGREEMENT


This Agreement sets forth the entire agreement between the parties with regard to

the subject matter hereof. No other agreements, representations, or warranties

have been made by either party to the other with respect to the subject matter of

this Agreement, except as referenced herein.



GOVERNING LAW


This Agreement shall be governed by and construed in accordance with the laws of

the State of Connecticut, without regard to conflicts of laws provisions, sole and

exclusive jurisdiction for any action or proceeding arising out of or related to this

agreement shall be an appropriate state or federal court located in the State of

Connecticut. Any cause of action you may have with respect to your use of this Web

Site must be commenced within one (1) year after the claim or cause of action

arises.



NO PARTNERSHIP


Nothing contained herein shall be deemed to establish a partnership, joint venture,

association, or employment relationship between the parties.



WAIVER


The failure by Fleetwood Asset Management Ltd. to enforce any provision of this

Agreement shall not constitute a waiver of any provision or right.



SEVERABILITY


If any of the provisions of this Agreement are found or deemed by a court to be

invalid or unenforceable, they shall be severable from the remainder of this

Agreement and shall not cause the invalidity or unenforceability of the remainder of

this Agreement.



CONTACT


If you have any questions about these Terms of Use, you can contact Fleetwood

Asset Management Ltd., 1 Merwin Avenue, #A2, Milford, CT 06460.

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