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AGP LP 519 Alpha Group Caudal Paul Barren
Item 12.
Brokerage Practices
Subject to the investment guidelines and restrictions imposed by clients, Alkeon generally has
the authority to determine, without specific client consent, the securities and amounts thereof to
be purchased or sold. In selecting brokers or dealers to execute transactions, Alkeon need not
solicit competitive bids and does not have an obligation to seek the lowest available commission
cost or to negotiate "execution only" commission rates. In selecting brokers and negotiating
commission rates, Alkeon may take into account, among other things the execution capability
and quality, financial stability, reputation, difficulty of executing the order, capital commitment,
or whether the order is to be executed at the market or worked over time and brokerage and
research services provided by such brokers. Under no circumstances does Alkeon consider the
marketing efforts of broker-dealers on behalf of the funds for which it serves as investment
adviser in selecting broker-dealers to execute trades. Such marketing efforts include the sales of
the funds advised by Alkeon. However, some broker-dealers that effect securities transactions
for the funds will have a relationship with Alkeon or its affiliates to market the funds or other
investment vehicles managed by Alkeon or its affiliates.
Alkeon may also purchase from a broker or allow a broker to pay for the following (each a "soft
dollar" relationship):
•
research reports, services and conferences, including third-party research fees;
•
technical data;
•
periodical subscription fees;
•
consultations;
•
performance measurement data;
•
on-line pricing;
•
news wire and data processing charges; and
•
quotation services.
Alkeon may receive soft dollar credits based on certain principal, as well as agency, securities
transactions with brokers or direct a broker that executes transactions to share some of its
commissions with a broker that provides soft dollar benefits to Alkeon.
During Alkeon's last fiscal year, it acquired products and services with client brokerage
commissions or markups including, but not limited to: research from independent research firms,
order management systems, market data, consultation firms and industry news services and
publications.
In some instances, Alkeon may receive a product or service that may be used for both research
and non-research purposes (e.g. an order management system, trade analytical software or proxy
17
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
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