GRI Equity - sustainable success

As September draws to a close Dr Pratchett reminded me at his new book launch that “When you're standing on your doorstep with a sword in your hand, its too late!”. Quoting from “Monstrous Regiment”, a story playing on the jingoistic belligerence of humanity, this quote reflects the futility of knee-jerk reactions to crisis. People think that a heart attack is what is needed before a person will start eating more healthily and de-stressing their lifestyle. That might be tolerable on an individual level, but this planet can not afford a “heart attack” - there is no doctor to resuscitate it – so prevention is the only option. Pratchett's latest book Going Postal partly plays on the viciousness of SOME financiers and businesses, so friends, watch out for razor sharp humour on the world of money from the world's leading contemporary author.

The roundup is getting busier and busier and we are having to omit references in the interests of time and digestibility - apologies. Some have said that the roundup is “political”. However this may be, it is not partisan. We have no political affiliations and "we call it as we see it" based on a very wide perspective from the bogs of Ireland to global boardrooms. We do change our opinions as we learn more. We hope you will continue to enjoy our integrated review, from the soul.

Activities

I'm very much looking forward to the Spirit in Business gathering in Zurich. The calibre of people – investors, managers, advisors, entrepreneurs – is very high. The available papers (including our report) are posted here.

Our resources are running at full capacity now, with research and development, portfolio management and venture capital activities all picking up. October is likely to be exciting.

Perspective and Market Commentary

There is increasing evidence that consumption patterns are going to change faster and more radically than we imagine: oil, demographics, trade, food, water, natural services, booming demand for happiness, seeking spiritual uplift. I came across some picturesque illustrations of how challenging this is going to be. Here are some:

On demographics: "The 2003 Aging Vulnerability Index" by Neil Howe and Richard Jackson states " Today, there are 30 pension-eligible elders in the developed world for every 100 working age adults. By the year 2040, there will be 70. In Italy, Japan, and Spain, the fastest-aging countries, there will be 100."

On trade: from John Mauldin's newsletters which I continue to enjoy and recommend: "The [trade] subsidies will go, not because it is the right thing to do or because developed countries want to allow third world farmers a better life, but because at some point in the future there will simply be no money in the governmental coffers. there are going to be difficult choices in the future. Farm subsidies or pensions? Count the votes to see who wins. There are more elderly than there are farmers. A whole lot of something's will have to give to fund government guaranteed benefits and health care, and among them will be the farm subsidies. ... The World Trade Organization ruled that Europe is unfairly subsidizing sugar (they clearly are) and that the United States is unfairly subsidizing cotton (we clearly are, which is shameful for a country that promotes free trade). ..."

Intellectual property is on my mind because of involvement in several debates on its role in business development, profits and investment opportunities. The classic argument is that IP protection can provide massive gross margins (80% for Intel chips, 99% for MS operating software). These margins are said to be ethically justified by the high front end R&D costs (indirect) and high infrastructure costs (indirect) required to produce at economies of scale. This analysis reflects traditional thinking. Businesses evolving more dynamic business models, customer focused strategies and triple bottom line analysis must consider other factors. In particular, expansion of open technology forces businesses to consider the risk of not being able to reap super-profits because parallel technology development can remove the IP advantage before protection expires.

Also important is the rising awareness of investors and fiduciaries of the ingredients of profit in a company and their willingness to penalise a company for inconsiderate (anti-social) pricing. And at the simplest level of global development, rapid technology transfer to resource poor economies at affordable prices is one of the best methods of creating wealth in emerging economies, which creates opportunities and markets for higher value-added businesses, and reduces the tension of inequality that drives terrorism. In consideration of this evolving system change, businesses should consider more critically their investment in other business dimensions to provide value for money on a long term basis. Technology development will remain a core skill of any business in the information age, but remember that the majority of motivation of developers of technology (the scientists and engineers) is not profit but passion to “make a better mousetrap”. And if technology is to be the key competitive dimension, developed economies are not the place to be investing – emerging economies, especially Asia, invest more in education and are becoming a principal resources base of knowledge workers (eg outsourcing).

An excellent new study by the World Bank, “Doing Business in 2005”, shows that red tape is one of the chief obstacles to growth in almost all poor countries. In Haiti, for example, it takes 203 days to register a new company, which is 201 days longer than in Australia. The World Bank estimates that if a country in the worst-regulated quartile were to join the best quartile, it would boost its annual growth rate by 2.2 percentage points. In other words, there is probably much more to gain from slashing red tape than from begging for more aid. The report, however, which benchmarks regulatory performance and reforms in 145 nations, finds that poor nations, through administrative procedures, still make it two times harder than rich nations for entrepreneurs to start, operate, or close a business, and businesses in poor nations have less than half the property rights protections available to businesses in rich countries.

The UN has published a useful data source: "Development and Globalization: Facts and Figures" available online.

Geopolitics

This month let's start with some lightness: On the David Letterman show Kerry cited these "Top Ten Bush Tax Proposals."

#10. No estate tax for families with at least two U.S. Presidents.
#9. W-2 form is now Dubya-2 forms.
#8. Under simplified tax code, your refund check goes directly to Halliburton.
#7. Reduced earned income tax credit is so unfair, it makes me want to tear out my lustrous, finely groomed hair.
#6. Attorney General Ashcroft gets to write off U.S. Constitution
#5. Texas Rangers can take business loss for trading Sammy Sosa.
#4. Eliminate all income taxes; just ask Teresa to cover the whole damn thing
#3. Cheney can claim Bush as a dependent
#2. Hundred-dollar penalty if you pronounce it "nuclear" instead of "nucular".
#1. Bush gets deduction for mortgaging our entire future.

We are all getting ready for the US election, and make no mistake it is WE - surveys have been ongoing in many countries to identify preferred candidates and everyone realises that the US impacts their lives and so they care. As we prepare it is interesting to see the relative commitment to democracy around the world. Dr Lehmann has highlighted a report from the CIA: "The population of the United States — at 293 million — is 23% larger than Indonesia's (238 million). The two countries are the world's second and third-most populous democracies, respectively, after India. However, 124 million Indonesians — or 80% of the country's 155 million registered voters — participated in the first round of Indonesia's presidential election in July 2004. That was nearly 20 million more votes than the 105 million Americans (67.5% of registered voters) who voted in the 2000 U.S. presidential election — making Indonesia the world's second-largest democracy in terms of voter turnout." And he shocked us with this fact: The Swiss canton of Appenzell did not grant women the right to vote until 1999 (from The Economist). This insular perspective has recently been reinforced as Switzerland voted to keep restrictions on allowing immigrants easier access to citizenship.

Terror Risk and War

An outpouring of media sympathy and public grief followed the killing of many children in Beslan, Russia. The tragedy is sad but insignificant compared to the deaths in Sudan or even neighbouring Iraq, both places where developed states can have more influence. What Beslan further highlighted is the regression of Russia to a dictatorship – the Kremlin issued gross misinformation to cover up blunders, as well as propaganda. This comes on the heels of the confiscation of Yukos, the major oil company, and the current reorganisation of Russia's administration with, for example, taking back the appointment of regional governors as opposed to local elections. Caution is advised.

It appears that terror risk in the US is even domestic now. Maureen Dowd a columnist of the NYT who has highlighted "W"'s insulated perspective as being "as if in a thermos rather than a bubble like most presidents", stated on TV that she is afraid for herself because of the administration's ability to behave as if without consequences.

After last month's collaborative remarks by Bush that saying he had "miscalculated" the post-war mood in Iraq and commenting on the War on Terrorism - "I don't think you can win it", the FT published an editorial proposing that withdrawal from Iraq should now be considered as an option, particularly in light of the fact that the majority of deaths have occurred since "W" declared victory in May 2003. There is certainly no easy nor simple answer, but new approaches of collaboration are essential.

Investment Management and Venture Capital

I keep coming back to the impression that many leaders, managers, fiduciaries, well many of us, are behaving like the populace in the Emperor's New Clothes. Risk and reality are in front of us but delude ourselves in to thinking that we can live by traditional rules of hierarchy, greed and fear. But I'm beginning to articulate a reason and thus a solution will follow. John Mauldin in his book Bull's Eye Investing presents a enlightening study:

"First, a researcher takes a deck of 52 cards and holds one card up. Watchers pay a dollar for the chance to win $100 if that card is picked out of the deck. Keep in mind the expected payout is 1/52 - 100 = 1.92. Las Vegas would quickly go broke with such odds. Then they are asked if they would like to sell their chances: roughly 80 percent would sell if they could, asking for an average price of $1.86. If you could get such a price, it would be a reasonable sell. For someone who could buy all 52 chances, it would be a good purchase or arbitrage. He would make a quick 3.18 percent.

"Now it gets interesting. The next time, someone is allowed to pick a card out of the deck and offered the same chance, but now he has a personal attachment to the card because he touched it. Only about 60 percent of those who picked cards were willing to sell their chances, and they wanted an average price of just over $6. And when this same trick was performed at MBA schools the average sale price has been over $9.

"I know this card. I have studied it. I have a personal involvement with the card; therefore it is worth more," thinks the investor. Of course, it is worth no more than in the first case, but the psychology of "owning" the card makes investors value it more."

This psychology also helps explain a characteristic that befuddles me - why so often investors and entrepreneurs (especially) decline to hear or take advice based on years of training and experience!

Similarly I suppose the problem is that people don't like to hear the truth when we can ignore it or turn away. We prefer to hear something positive, like “we're winning”, not something challenging like “ we're not sure”, “its not going as planned”, or “we'll have to make some changes” even if the course recommended will plainly get better results, quicker.

On the listed stocks front, we expected downward movement in September and this proved to be the case for the DJIA but the FTSE All share improved.

While volatility remains high and the outlook for a long term bear remains, we are comfortable with many companies. If any change in our approach is occurring it is to focus more on "sustainable" companies because the evidence of competitive returns and lower risks continues to mount. (We have made some portfolio adjustments which members can access.)

Some good news for mutual fund investors: Beginning early next year, the Securities and Exchange Commission will require mutual fund managers to disclose their personal stakes in the funds they run. They'll also stop the widespread practice of "directed brokerage". The new rules also require fund companies to reveal how they compensate their managers. That's another great leap forward. Being able to take the measure of a manager's financial incentives will provide yet another important clue as to just how shareholder-friendly a fund shop really is.

A report titled ‘Towards Transparency: progress on global sustainability reporting 2000’, covering Europe, The Americas, Africa, and Asia & Australasia found that only around 2000 companies are engaged in producing non-financial reports, which makes our screening somewhat easier. However, the findings stress a need for marked improvements in coverage, standards and credibility among companies over the next few years.

The demands for improved ethics in business are increasing. The deadline for compliance with Sarbannes-Oxley requirements is January 2005 and few companies are ready. The major banks and financial service companies are rushing to implement systems that should have been planned more than a year ago and will not be in compliance, though there will be considerable whitewash to attempt to give the impression of compliance. Improvements in culture have not been made however and shareholders and clients are still exposed to similar conflicts of interest and “Enron” risks. The Chairman of the SEC noting that although corporate governance has improved, many US bosses still fail to provide ethical leadership for their companies.

Three University of Pennsylvania professors have co-authored a paper entitled How Important is Corporate Governance?. The paper examines 14 corporate governance factors (distilled from 39 corporate governance measures) at more than 2,100 firms. "Overall, our results suggest that the typical structural indicators of corporate governance used in academic research and institutional rating services have very limited ability to explain managerial behavior and organizational performance," the abstract states. This enhances our recommendation for authentic, sustainable culture. For CEO's and owners wishing to build coherent, flexible and resilient cultures we can recommend a number of world leading guides and trainers or contact our partners Spirit in Business.

As Socially Responsible Investment Grows in Japan, FTSE4Good launched a new index exclusively for Japan following on the introduction of the first SRI index by Morningstar Japan last year.

Technology investors should be cautious about getting too optimistic. Many of the biggest tech companies, such as Hewlett-Packard, Intel, and Cisco, have had spiraling inventories over the last few quarters. Inventories rise as companies anticipate an increase in sales; a company caught short with insufficient supply in the face of rising demand risks sending its customers off to competitors to fill their orders. But the risk in rising inventories is that sales do not improve and this has started happening. In the second half of the year companies such as Intel have stated that customers were delaying orders, and as a result these companies were going to burn off inventory to respond to the "soft spot" in sales. Unfortunately, it's not the soft patch that is to be short-lived, it was the spike that was temporary in nature. Integrated circuit manufacturer Xilinx warned that its guidance was too high and its days inventory outstanding actually rose substantially to 155 days - that's nearly a half-year's worth of products sitting on the company's shelves at a time when the company says sales are down dramatically from its Asian clients because of "excess inventories held by U.S.-based customers."

Venture capitalists will be interested in a virtual marketplace for innovation futures. MIT's Innovation Futures online trading system uses the marketplace's own predictive tools to help researchers and investors assess how innovative (and competitive) a nation is. Like other forms of futures trading, Innovation Futures puts a number (the trading price) on the likelihood of an event occurring. But rather than forecasting demand for pork bellies, the Innovation Futures traders are forecasting venture-capital investment, chip prices, the extent of broadband connection, and other indicators of innovativeness. Innovation Futures has now teamed with the Cambridge-MIT Institute to offer a predictive marketplace for innovation in the United Kingdom. The goal is to consolidate information from disparate sources on where innovation is taking place and the amount of resources being put into research and development of innovative ideas and products. The Cambridge-MIT Institute, Innovation Futures.

Interest Rates and Inflation

Occasionally we review and take a position on interest rates. Our view has not changed for six months but we are now in the process of reconsidering the dynamics. Inflation is now entering an uncertain domain and although we don't expect radical news immediately over the next quarter signs of change are expected. More interestingly it appears that a strategic financing opportunity may be presenting itself: long term rates low, short term rates rising. If your exposure is significant we suggest monitoring development and taking professional advice.

Trade

In The Next Economy Craig Barrett, CEO of Intel, argues that to create jobs at home, the United States must forgo protectionism and embrace innovation.

The UK expects to write off its share of debts owed by the world's poorest countries and will encourage other rich nations to do the same in a bid to lift the burden of debt repayments from Third World nations. The UK holds about 10% of the total debt owed to the World Bank and other development banks. This will greatly enhance their ability to develop out of poverty.

Energy

Oil prices remain high and consumption continues to rise - supply can not keep pace. Alternative sources are required now, not just to satisfy demand but because the disruption to the biosphere is becoming irreversible. US oil leapt to its highest level since the early 1980s, as concern grew about disruption to world supplies. Traders said fears about political unrest in Nigeria's oil producing region were putting pressure on prices. Other factors included the slow return of US output after Hurricane Ivan, low US stocks and fears about Iraqi supply and Russian supply as systems deteriorate, Yukos is restricted from operating and Putin strangles freedoms.

Tony Blair came out of the closet in September. He warned that climate change will result in "catastrophic consequences" for the world unless the major economies agree on immediate and decisive action to combat it. He promised to lead a new crusade to persuade the international community to act during Britain's year in the presidency of the G8 leading industrial nations, starting in January. He said that provided a "wonderful opportunity" and, despite the divisions over the Kyoto Treaty, he insisted an agreement was "achievable". Global warming is increasing at a rate that was "simply unsustainable in the long term ... I do not mean centuries ahead. I mean within the lifetime of my children certainly; and possibly within my own. ... On most issues we ask children to listen to their parents. On climate change, it is parents who should listen to their children. Now is the time to start."

In Ireland the government department that controls the state electricity company has decided to get its electricity from a cheaper supplier. In an unprecedented step, the Department of Communications is abandoning the State electricity supplier and opting for a "green" energy source instead. It is likely several other government departments and state agencies will also seek tenders from 'green' energy suppliers in what will amount to a radical shake-up of the electricity market.

Asia

It seems that Bird Flu is back and maybe a bit early. The only sensible advice - eat organic!

Hong Kong election positive because 62% voted for democrats even though they only won 25/60. Voter turnout was high, higher than north America or Europe.

Also in Thailand, elections for the governor of Bangkok were positive because of teh apparent lack of corruption. Although not confirmed, our partners in Bangkok report that there was not the usual talk of Bt 500 per vote, but decisions on policy. Realistically, this is a small step for Thailand towards an efficient flat political structure, but it is a step in the right direction.

The highlights of ASRiA's successful conference included the IFC's call for the private equity community to set social and environmental due diligence standards, in depth discussion of supply chain issues, new SRI fund performance data, and a close look at how investors and activists are approaching the deforestation issue. Please see conference notes here.

The Malaysian Prime Minister intends to make integrity the cornerstone of his administration. Appreciating the urgent need for change, the Malaysian premier introduced the National Integrity Plan to provide direction for all sectors to participate towards enhancing ethical values and integrity. It will be interesting to see how this transpires in a country which is not know for transparent dealings or politics. Additional positive news was the release of Dr Anwar Ibrahim - we certainly felt his pain at the injustice of the process that incarcerated him and wish him well in all new endeavours.

(Congratulations to Pan and Pock. I wish I could have been there! Engagement photos here - lovely.)

IT and CT

Just when you thought it was safe to read your email, computer security company Symantec said there has been a 400% increase in new viruses and worms aimed at Microsoft's Windows operating systems. Over 5,000 new worms and viruses were documented in the first half of the year, compared to 1,000 last year over the same time period. Microsoft has also issued a warning about a critical vulnerability in Windows that could let carefully crafted pictures act as bearers of malicious code. The flaw was found in the code that the operating system and other Windows programs use to display images prepared in the popular Jpeg format.

There are also increasing signs that Microsoft indeed recognizes that it might want to change the way it does business. The company recently announced that it would provide a stripped-down version of Windows XP for sale in Thailand. In some emerging markets, particularly in Asia, Linux has been become a compelling choice for both financial and security reasons.

Mid-September brought an unusual piece of news: End of the world wide web 'is nigh' Some computer and communications companies including Cisco, Hewlett-Packard and AT&T, share the fears of an imminent internet collapse and are working to find a solution. Predicting a future which would horrify many businesses and email addicts, some experts fear the internet could soon crumble under the weight of its users. And the problem will only get worse as more people from developing countries start to sign on to the information superhighway. Patrick Gelsinger, the chief technology officer for computer company Intel, delivered the warning at his company's technical conference. "We're running up on some architectural limitations," he said. It seems rather unbelievable, but would have catastrophic consequences is it occurred - the Millenium Bug without a solution! Watch this space for more news.

LOHAS

Newsweek had an extensive cover story in collaboration with Harvard Medical School – The Science of Mind and Body. A review is posted here, but it would be too much for this roundup. It is strongly recommended - a few simple tricks or behavioural changes can apparently reduce your medical bills, increase your productivity (and fertility!), reduce stress and increase happiness - no drugs required!

For those passionate enough to want to change the world, check out the Global Ideas Bank a stimulating resource of alternative solutions to a range of challenges.

And those feeling exhausted from trying but making slow progress, I hope this extract from a letter received recently will provide some uplift:

"How can I as one person change what is happening in our government and our world?" By becoming a spiritual activist, and by being that spark to help others raise their awareness and find peace. By committing to creating peace within yourself and your family, by voting and encouraging others to vote for political leaders who value humanity, and by helping others discover their light, you set in motion the intention of positive transformation.

If one by one each of us takes personal responsibility for raising the awareness of humanity we begin to shift the global consciousness.

There is a powerful phenomenon in group behavior called reaching a critical mass. What this means is that one person begins initiating a behavior, others observe it and begin imitating the action. Then one by one others join in until enough people are behaving in the same way and the entire crowd follows: this is the critical mass.
I personally witnessed this phenomenon over the weekend when my husband and I took our children to a Marlin's game. The stadium was filled with the energy of 25,000 people, each an individual brought together for the collective purpose of enjoying an afternoon of baseball. My six-year-old daughter Riley, who is very wise and observant, was fascinated by the crowd. As she looked around with determined eyes she leaned over and said, "Mommy, do you think I can get the whole stadium to start doing the Marlins cheer?" I told her, "Go for it and see what happens..."

She began very quietly chanting, "Lets go Marlins," then she looked around and noticed that her father, brother, and I were chanting with her. She became more confident and began cheering louder. The section behind and in front of us joined in. Within moments all 25,000 people erupted in a frenzy chanting "Lets Go Marlins." My daughter beamed, knowing that she ignited a spark of inspiration and passion that spread so quickly.

Education and health find themselves under inspection in teh US as the National Union of Teachers (NUT) is again calling for government to take action against fast food and junk food advertising aimed at young children, in response to increasing levels of diet-related ill health and obesity. As part of an on-going campaign for greater government investment into health education programs, which has been running for several years, NUT is calling for tighter controls on food advertising. According to General Secretary Doug McAvoy "There has been a major increase in promotions by fast food manufacturers targeted directly at children. It is an issue which directly concerns schools. Poor diet and poor health are two sides of the same coin." As an organic gardener and teacher you can imagine that I find issues of this nature critical - especially when I see the litter of junk food wrappers around local schools and hear of the learning and behavioural problems associated with E42 etc.

America's biggest tobacco companies went on trial for deceiving the public over the dangers of smoking. The lawsuit was filed by the Clinton administration in 1999. The Bush administration was expected to drop the case, but instead had brought it to trial, and is seeking $280 billion from the cigarette-makers, who deny the charges. It seems a bit inappropriate given that times have changed so much. Even though it seems that criminal miseducation took place, it would have been know then by both business, science and government - they would have all been complicit - and probably consumers. I was never under any illusions about the health costs of smoking when I was ploughing through a pack a day!

A ten-year federal ban on the sale of assault weapons expired after Congress declined to re-authorise the legislation. The law, signed by Bill Clinton in 1994, outlawed the sale of 19 sorts of semiautomatic guns. Since then, some states have passed their own stringent versions of the law. However, a settlement by two gun manufacturers for the negligent distribution of weapons may open the door to further suits and settlements forcing teh gun industry to properly control distribution.

Chemical companies are also warned bv the failure of the bid by Unocal (UCL) to get an Alien Tort Claims Act (ATCA) case dismissed. Their request was rejected by the California Supreme Court. This decision opens the door for the case, which was initiated by fifteen Myanmar refugees who allege that the company is liable for murder, rape, and forced labor committed by soldiers guarding its gas pipeline, to proceed.

Conferences etc

It seems that October is a month of conferences. For your reference below are copied a number of announcements that have cross our e-desk.

ECO-PAGES 2004, the 1st bilingual directory of environmental contacts from all over the world, is now available for free. ECO-PAGES consists of over 7,500 environmental products and services providers from more than 140 countries.

AUSTRALIAN ETHICAL INVESTMENT ASSOCIATION (EIA) CONFERENCE, MELBOURNE, 14-15 OCTOBER
SRI QUANT is the leading SRI conference taking place in Australasia in 2004 featuring world renowned experts such as Dr Matthew Kiernan of Innovest and Dr Stephen Davis of GovernanceMetrics International who will demonstrate how to quantify the financial impact of corporate governance and environmental risk on portfolio return. Register today to meet Australasia's leading SRI practitioners.

CORPORATE RESPONSIBILITY CONFERENCE, HONG KONG, 14-15 OCTOBER This Ethical Corporation event, covering a range of presentations and workshops, will debate and discuss the state of corporate responsibility in Asia. Speakers include from leading companies such as Nestle Philippines, HSBC, Nike, Tata Motors, GlaxoSmithKline, Timberland Asia, Shell Hong Kong, MTR Corporation, adidas-Salomon and many others.

CHINA CORPORATE RESPONSIBILITY CONFERENCE, NEW YORK, 5-6 OCTOBER Ethical Corporation's "How to Make Corporate Responsibility Work in China?" will have top brands and other key players including major NGOs discussing the complex demands of managing corporate responsibility policy and practice in China.

6th ANNUAL SOCIAL ACCOUNTABILITY INTERNATIONAL (SAI) CONFERENCE, NEW YORK, 18 OCTOBER
SAI's 6th annual conference themed "Corporate Social Responsibility and Workplace Standards: Responsible Strategies for Global Sourcing" will bring together key stakeholders including buying companies, supplier companies, trade unions, government, investors, and human rights organizations to talk practical approaches to managing social accountability in the supply chain.

nvestors’ Circle 2004 National Conference and Venture Fair, Sunday October 24th through Tuesday October 26th at The Charles Hotel. The conference is aimed at reaching angel investors, professional venture capitalists, philanthropists and entrepreneurs who are using private capital to promote a transition to a sustainable future. Monday will feature a venture fair of up to 30 companies that are working to solve major social and environmental problems. Tuesday will feature speakers and panels will focus on discussions of double bottom line investing and enterprise creation.

International Business Exchange Forum Renewable Energy Oct. 21 & 22 - Fairground Augsburg (near Munich, Germany)

“Investing with Values” --- October 6, 5:00 - 8:30 pm, Denver (area), Colorado

This report has been prepared for information purposes and is not an offer, or an invitation or solicitation to make an offer to buy or sell any securities. This report has not been made with regard to the specific investment objectives, financial situation or the particular needs of any specific persons who may receive this report. It does not purport to be a complete description of the securities, markets or developments or any other material referred to herein. The information on which this report is based, has been obtained from publicly available sources and private sources which may have vested interests in the material referred to herein. Although GRI Equity and the distributors have no specific reasons for believing such information to be false, neither GRI Equity nor the distributors have independently verified such information and no representation or warranty is given that it is up-to-date, accurate and complete. GRI Equity, associates of GRI Equity, the distributors, and/or their affiliates and/or their directors, officers and employees may from time to time have a position in the securities mentioned in this report and may buy or sell securities described or recommended in this report. GRI Equity, associates of GRI Equity, the distributors, and/or their affiliates may provide investment banking services, or other services, for any company and/or affiliates or subsidiaries of such company whose securities are described or recommended in this report. Neither GRI Equity nor the distributors nor any of their affiliates and/or directors, officers and employees shall in any way be responsible or liable for any losses or damages whatsoever which any person may suffer or incur as a result of acting or otherwise relying upon anything stated or inferred in or omitted from this report.

Private and Confidential

September Comment