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Simple But Not Easy
by Richard Oldfield

A slightly autobiographical and heavily biased book about investing.

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I represent a UK local public authority or municipality ("LPA") which has been an active investor in the stock markets for more than 5 years.
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Large entity meeting at least two of the following size requirements on a company basis:
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I have been an active investor in the stock markets for more than 5 years.
I have invested in stock markets other than US markets.
I understand the nature of an investment in the funds managed by Oldfield Partners LLP, including the risks involved.
In light of the nature of an investment in the funds managed by Oldfield Partners LLP, I am capable of making my own investment decisions and understanding the risks involved.
I have the financial ability to bear the risk that I may get back less than the amount that I invested.

One of the following definitions applies to me:
1. The Account is a natural person whose individual net worth*, or joint net worth with that person’s spouse, at the time of his or her purchase exceeds $1,000,000.
2. The Account is a natural person who had individual income in excess of $200,000 in each of the last two calendar years, or joint income with that person’s spouse in excess of $300,000 in each of those years, and has a reasonable expectation of reaching the same income level in this calendar year.

* Net worth for this purpose means total assets (excluding primary residence) in excess of total liabilities. Total liabilities excludes indebtedness secured by the primary residence, provided that such indebtedness does not exceed the fair market value of such residence and was not incurred within 60 days of the date of the subscription hereby made.

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Large entity meeting at least two of the following size requirements on a company basis:
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2. Net turnover of EUR 40,000,000 (or equivalent)
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One of the following definitions must apply to my company:
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2. The Business Development Bank of Canada incorporated under the Business Developmanr Bank of Canada Act (Canada),
3. A subsidary* of any person* referred to in paragraph (A) or (B), if the person or company owns all of the voting securities of the subsidary, except the voting securities required by law to be owned by directors of the subsidary,
4. a person* or company registered under the securities legislation of a jurisdiction of Canada as an adviser, investment dealer, mutual fund dealer or exempt market dealer,
5. A pension fund that is regulated by either the federal Office of the Superintendent of Financial Institutions or a pension commission or similar regulatory authority of a jurisdiction of Canada or a wholly-owned subsidiary* of such a pension fund,
6. An entity organized in a foreign jurisdiction* that is analogous to any of the entities referred to in paragraphs (A) to (E),
7. the Government of Canada or a jurisdiction of Canada, or any Crown corporation, agency or wholly owned entity of the Government of Canada or a jurisdiction of Canada,
8. Any national, federal, state, provincial, territorial or municipal government of or in any foreign jurisdiction, or any agency of that government,
9. A municipality, public board or commission in Canada and a metropolitan community, school board, the Comité de gestion de la taxe scolaire de l'île de Montréal or an intermunicipal management board in Québec,
10. A trust company or trust corporation registered or authorized to carry on business under the Trust and Loan Companies Act (Canada) or under comparable legislation in a jurisdiction of Canada or a foreign jurisdiction*, acting on behalf of a managed account* managed by the trust company or trust corporation, as the case may be,
11. A person* or company acting on behalf of a managed account* managed by the person or company, if the person or company is registered or authorized to carry on business as an adviser or the equivalent under the securities legislation of a jurisdiction of Canada or a foreign jurisdiction*,
12. An investment fund* if one or both of the following apply:
  1. the fund is managed by a person* or company registered as an investment fund manager under the securities legislation of a jurisdiction of Canada;
  2. the fund is advised by a person* or company authorized to act as an adviser under the securities legislation of a jurisdiction of Canada
13. A registered charity under the Income Tax Act (Canada) that obtains advice on the securities to be traded from an eligibility adviser, as defined in section 1.1 of NI 45-106, or an adviser registered under the securities legislation of the jurisdiction of the registered charity,
14. A person* or company that is entirely owned by an individual or individuals referred to in paragraph (O) of the definition of 'permitted client', who holds the beneficial ownership interest in the person or company directly or through a trust, the trustee of which is a trust company or trust corporation registered or authorized to carry on business under the Trust and Loan Companies Act (Canada) or under comparable legislation in a jurisdiction of Canada or a foreign jurisdiction,
15. A person* or company, other than an individual or an investment fund, that has net assets of at least C$25 million as shown on its most recently prepared financial statements,
16. A person* or company that distributes securities of its own issue in Canada only to persons* or companies referred to in paragraphs (A) to (N), or to an individual or individuals referred to in paragraph (N) of the definition of 'permitted client' under NI 31-103

*As defined under NI 31-103 and related definitions

I confirm that:

I have been an active investor in the stock markets for more than 5 years.
I have invested in stock markets other than Canadian markets.
I understand the nature of an investment in the funds managed by Oldfield Partners LLP, including the risks involved.
In light of the nature of an investment in the funds managed by Oldfield Partners LLP, I am capable of making my own investment decisions and understanding the risks involved.
I have the financial ability to bear the risk that I may get back less than the amount that I invested.

The following definition applies to me:
An individual who beneficially owns financial assets, as defined in section 1.1. of NI 45-106, having an aggregated realizable value that, before taxes but net of any related liabilities, exceeds C$5 million.

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