1.  A Hedge Fund Manager should establish management policies and practices appropriate for its size, nature, and complexity and for its trading activities for each Hedge Fund it manages.

1. A Hedge Fund Manager should establish management policies for trading activities documentation, NAV determination, risk analysis, compliance, and other key areas as appropriate. A Hedge Fund Manager should adopt an organizational structure that facilitates effective oversight to ensure compliance with the established management policies. A Hedge Fund Manager should review its policies and practices at least annually and update them as appropriate (e.g., to reflect changes in structure or strategy, extraordinary market events, or new applicable regulations).

2. A Hedge Fund Manager should determine the investment, risk, and trading policies for each Hedge Fund it manages based on the specific investment objectives described in the respective Hedge Fund’s offering documents.

2. A Hedge Fund Manager should allocate capital and risk among portfolio managers, strategies, asset classes, and other relevant categories, to fit each Hedge Fund’s performance objectives and targeted risk profile. A Hedge Fund Manager should periodically re-examine allocations and adjust them as appropriate. In addition, a Hedge Fund Manager should establish appropriate trading parameters and risk limits for each allocation, as these parameters fit into the portfolio. The Hedge Fund Manager should adjust the trading parameters and risk limits as necessary to reflect various market and other changes.  (See also Section 4 - Risk Management).