The distribution policy of the Company, as contained in the Company’s Articles of Association, states that the Directors may provide returns to Shareholders by establishing a distribution programme whereby profits from realisations made during the year will be used to implement a tender offer to repurchase Ordinary Shares at a price equal to the last published Net Asset Value per Share. Under such a distribution programme, the Company will announce to holders of Ordinary Shares the implementation of the tender offer giving the right to all holders of Ordinary Shares to participate in the repurchase. In the event that the value of the Ordinary Shares submitted by holders to the Company wishing to participate in the tender offer exceeds the funds available, the Company will purchase Ordinary Shares from holders pro rata. VNL expects to initiate its first tender offer in 2011, as announced in the 28 November 2010 announcement on VNL’s distribution policy.