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Value Catalyst Fund Limited (T (VCF)

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Friday 06 November, 2009

Value Catalyst Fund Limited (T

Investing Policy

6 November 2009

                 The Value Catalyst Fund Limited ("the Company")

                                Investing Policy

The  Company announces its investing policy pursuant to Rule 8 of the AIM  Rules
for Companies.

Investing Policy

VCF  seeks  to  generate positive investment returns through  a  combination  of
capital  growth and the payment of an annual dividend. It aims to  achieve  this
based  on  the  experience and ability of the Investment Adviser in  identifying
opportunities  to eliminate or reduce discounts to the fair value of  closed-end
funds  and  other  asset  based  investments.   It  does  this  is  by  actively
encouraging  improved corporate governance via management, shareholders,  boards
and advisers of the investment companies.

VCF  seeks to both enhance returns and reduce risk through the selective use  of
gearing  of  up to 200 per cent. of net asset value and derivative products.  In
cases where the Company forms a negative view of the underlying assets, it seeks
to  hedge the risk of the underlying assets so as to limit the exposure only  to
the value of the discount of the share price to the intrinsic value.

The  decision to hedge and to what level, is based on an assessment of the  cost
and  the  likely  effectiveness of any such action.   Hedging  costs  also  vary
dependant on the financial instrument that is being hedged. VCF aims to  be  net
long with a target exposure of approximately 50 per cent. to the market.

VCF has the following investment restrictions:

(a)   no  more  than 25 per cent. of the gross assets of VCF,  at  the  time  of
investment,  may be lent to or invested in the securities of any one  closed-end
fund or other issuer;

(b)   no  more  than 25 per cent. of the gross assets of VCF,  at  the  time  of
investment,  may  be  exposed to the creditworthiness or  solvency  of  any  one
counterparty other than the Prime Broker; and

(c)   VCF  may  not use derivatives unless it adheres to the principle  of  risk

This    policy    is    also   set   out   on   the   Company's    website    at


Azhic Basirov / Siobhan Sergeant
Smith & Williamson Corporate Finance Limited
Tel +44 (0)20 7131 4000