Regulated by Cyprus Securities and Exchange Commission License CIF 038/04

LIST OF INVESTMENT STRATEGIES AND BENCHMARKS CALCULATION POLICY FOR THE CLIENT PORTFOLIOS
The present Policy is the document open for public access and it contains the list of Investment Strategies and methods of calculation and determination of the following benchmarks for the Portfolios of Portfolio Management Clients of MDM Investments Limited: 1. 2. 3. 4. (MICEX CBI TR), (MICEX Index), (RTS Index), (Capital Protection Benchmark),

TABLE OF BENCHMARKS CORRESPONDING TO INVESTMENT STRATEGIES STRATEGY BONDS strategy HIGH YIELD BONDS strategy CAPITAL PROTECTION strategy CLASSICAL BALANCED strategy EQUITIES strategy EQUITIES GROWTH strategy TREND GROWTH strategy BENCHMARK MICEX CBI TR MICEX CBI TR Capital Protection Benchmark 50% MICEX CBI TR + 50% MICEX Index RTS Index RTS Index MICEX Index BONDS STRATEGY

Bonds of Russian issuers: 80%-100%; Deposits in Russian Rubles with credit institutions: 0%-20%; Futures based on bonds of Russian issuers and/or rates for short-term loans: 0%-10% (nominal volume of contractual obligations); Monetary funds: 0%-5%. Benchmark: MICEX CBI TR.

Within the process of portfolio management the Portfolio Manager performs a Bonds investment strategy. In accordance with this strategy the Portfolio Manager shall use endeavors for safekeeping and increase in value of property subject of portfolio management mainly through coupon yield on bonds, as well as increase of bonds value. List of appropriate investment objects: the assets shall be invested into the following instruments:

Portfolio management objective: to make efforts for safekeeping and increase in value of assets under portfolio management.

INVESTMENT STRATEGIES AND BENCHMARKS 1

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Bonds of Russian issuers: 80%-100%; Deposits in Russian Rubles with credit institutions: 0%-20%; Futures based on bonds of Russian issuers and/or rates for short-term loans: 0%-10% (nominal volume of contractual obligations); Monetary funds: 0%-5%. Benchmark: MICEX CBI TR. Portfolio management objective: to make efforts for safekeeping of assets under portfolio management. CAPITAL PROTECTION STRATEGY

Within the process of portfolio management the Portfolio Manager performs a High Yield Bonds investment strategy. In accordance with this strategy the Portfolio Manager shall use endeavors for increasing in value of property subject of portfolio management mainly through coupon yield on bonds with high levels of credit risk. List of appropriate investment objects: the assets shall be invested into the following instruments:

Portfolio management objective: to make efforts for increase in value of assets under portfolio management.

HIGH YIELD BONDS STRATEGY

Bonds of Russian issuers and/or deposits in Russian Rubles: 80%-100%; Deposits in Russian Rubles with credit institutions: 80%-100%; Options on futures based on RTS index and/or separate shares of Russian issuers: 0%-20% (option premium); Monetary funds: 0%-5%. Benchmark: Capital Protection Benchmark. Portfolio management objective: to use endeavors in order to outperform the relevant benchmark. CLASSICAL BALANCED STRATEGY

Within the process of portfolio management the Portfolio Manager performs a Capital Protection investment strategy. In accordance with this strategy the major part of the amount transferred by the owner of assets shall be invested in bonds of Russian issuers and/or in deposits. Minor part of the amount invested shall be used for purchasing options on futures based on RTS index and/or separate shares of Russian issuers. An income receivable from investing in bonds may guarantee safekeeping of the amount invested. An income, receivable in case of exercising an option, may guarantee additional increase in value of assets under portfolio management. List of appropriate investment objects: the assets shall be invested into the following instruments:

Within the process of portfolio management the Portfolio Manager performs a Classical Balanced investment strategy. In accordance with this strategy the quantity of Shares in the Clients portfolio shall be increased while the prices of shares go down and the quantity of bonds decreases. When the prices of shares go up, the quantity of Shares in the Clients portfolio decreases and the quantity of Bonds increases. List of appropriate investment objects: the assets shall be invested into the following instruments: Bonds of Russian issuers: 45%-55%; Shares of Russian issuers: 45%-55%; Monetary funds: 0%-5%. Benchmark: 50% MICEX CBI TR + 50% MICEX Index.

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Regulated by Cyprus Securities and Exchange Commission License CIF 038/04

Portfolio management objective: to use endeavors in order to outperform the relevant benchmark.

EQUITIES STRATEGY

Within the process of portfolio management the Portfolio Manager performs an Equities investment strategy, according to which a portfolio comprised of shares shall be formed. Shares shall be selected on the basis of sequential analysis of economy in general, economy sectors and several issuers of shares. The portion of each sector and any issuer of shares in the Clients portfolio depends on their attractive fundamentals. The change in quantity of a sector and/or any issuer of shares in the Clients portfolio shall be effected in case of a change of fundamentals of a sector and/or an issuer of shares. Within the portfolio management the Manager may, depending on the current situation, hedge the portfolio by selling future contracts on indices or separate shares. Within the portfolio management the Manager shall use endeavors to invest all funds in Shares, with the exception of funds which serve as a collateral for obligations under future contracts. Shares of Russian issuers: 75%-100%; Derivative contracts: 0%-25% (nominal volume of contractual obligations); Monetary funds: 0%-25%. EQUITIES GROWTH STRATEGY List of appropriate investment objects: the assets shall be invested into the following instruments:

Benchmark: RTS index.

Portfolio management objective: to use endeavors in order to outperform the relevant benchmark.

Within the process of portfolio management the Portfolio Manager performs an Equities Growth investment strategy, under which it shall form a portfolio comprised of shares of several issuers, having a high level of increase in market value of shares potential. The portion of any issuer of shares in the Clients portfolio depends on its attractive fundamentals. The change in quantity of any issuer of shares in the Clients portfolio shall be effected in case of a change of attractive fundamentals of such issuer of shares. Within the portfolio management of Assets the Company shall use endeavors to invest all funds in shares. The portion of funds in Assets is minimal and may arise as a temporary measure in periods between the transactions of purchasing and/or selling of Shares. List of appropriate investment objects: the assets shall be invested into the following instruments: Shares of Russian issuers: 85%-100%; Monetary funds: 0%-15%.

Benchmark: RTS index.

Within the process of portfolio management the Portfolio Manager performs a Trend Growth investment strategy, under which it forms a portfolio comprised of Shares and/or Derivative contracts. Purchase and/or sale of Shares and/or Derivative contracts shall be performed on the basis of technical analysis of movement of price and market indices for the last year. Any changes in Clients portfolio shall be effected for the purposes of income fixing as well as for the purposes of loss fixing with the aim of its limitation. When no steady movement of prices for shares and/or derivative contracts is expected, the Portfolio manager can acquire Bonds or otherwise the Clients Assets may consist of funds.
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Portfolio management objective: to use endeavors in order to outperform the relevant benchmark.

TREND GROWTH STRATEGY

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Benchmark: MICEX index

Shares of Russian issuers: 0%-100%; Bonds of Russian issuers: 0%-100%; Derivative contracts: 0%-100% (nominal volume of contractual obligations); Monetary funds: 0%-100%.

List of appropriate investment objects: the assets shall be invested into the following instruments:

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Regulated by Cyprus Securities and Exchange Commission License CIF 038/04

BENCHMARK CALCULATIONS 1 MICEX CBI TR

Definition

MICEX CBI TR stands for Corporate Bond Index Total Return. It is a bond market index, which assumes reinvestment of coupon payments, calculated and published by MICEX. Basic Data The information on the value of the index can be derived from the official Internet web-page of the exchange: www.micex.ru Benchmark Calculations The Benchmarks value on i-th day is calculated as follows: where

B = MICEX _ CBI _ TR i i

MICEX_CBI_TRi the closing value of MICEX CBI TR on the i-th day, or, if the i-th day is not a Business Day, the closing value of the index on the Business Day, immediately preceding the i-th day. MICEX Index

Definition

MICEX Index is a stock market index calculated and published by MICEX. Basic Data

The information on the value of the index can be derived from the official Internet web-page of the exchange: www.micex.ru Benchmark Calculations The Benchmarks value on i-th day is calculated as follows: where

B = MICEX i i

MICEXi the closing value of MICEX Index on the i-th day, or, if the i-th day is not a Business Day, the closing value of the index on the Business Day, immediately preceding the i-th day.

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Regulated by Cyprus Securities and Exchange Commission License CIF 038/04

Classical Balanced Strategy Benchmark

Definition

Classical Balanced Strategy Benchmark is comprised of the numeric series of data calculated on the basis of closing values of MICEX Index and MICEX CBI TR of each Business Day. Basic Data The information on the value of the indices can be derived from the official Internet web-page of the exchange: www.micex.ru

Benchmark Calculations

The Benchmarks value on i-th day is calculated as follows: where

Bi = Bi 1 K i

Bi-1 the value of Benchmark on the Business Day immediately preceding the i-th day. Ki the value of the Benchmarks Multiplier calculated on i-th day. The value of Benchmarks Multiplier (Ki) on i-th day is calculated as follows: where

K i = 0.5

Micexi CBI _ TRi + 0.5 Micexi 1 CBI _ TRi 1

Micexi the closing value of MICEX Index on the i-th day; Micexi-1 the closing value of MICEX Index on the Business Day immediately preceding the i-th day; CBI_TRi the closing value of MICEX CBI TR on the i-th day; CBI_TRi-1 the closing value of MICEX CBI TR on the Business Day immediately preceding the i-th day; The value of Benchmark (B1) on the first day of calculations is taken equal to 100. 4 RTS Index

Definition

RTS Index is a stock market index calculated and published by RTS. Basic Data

The information on the value of the index can be derived from the official Internet web-page of the exchange: www.rts.ru Benchmark Calculations The Benchmarks value on i-th day is calculated as follows:

B = RTS i i
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INVESTMENT STRATEGIES AND BENCHMARKS

Regulated by Cyprus Securities and Exchange Commission License CIF 038/04

RTSi the closing value of RTS Index on the i-th day, or, if the i-th day is not a Business Day, the closing value of the index on the Business Day, immediately preceding the i-th day. 5 Capital Protection Benchmark Definition

where

As the Capital Protection strategies main goal is to preserve the investors funds if the situation on the stock market is not developing as expected, then benchmark for valuing the portfolio management results is taken to be equal 0% annually. That means that any non-negative return to the portfolio is better than benchmark.

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