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Foxhall Capital Management, Inc. is a registered investment advisor with the US Securities and Exchange Commission (SEC) under the Investment Advisor’s Act of 1940. Effective 11/1/2011, the Foxhall Capital ETF Series was renamed the Foxhall Capital Global Series and the firm was redefined to include the Global Allocation Strategy. The “firm” includes various Foxhall Capital Global and 401(k) strategies in bundled fee and non-bundled fee accounts for primarily US clients. The “entity” is defined as the Foxhall Capital Global Series, the Global Stock Series, 401(k) Series and the Variable Insurance Series. A complete list and description of all firm composites are available upon request.

FOXHALL CAPITAL MANAGEMENT CLAIMS COMPLIANCE WITH THE GLOBAL INVESTMENT PERFORMANCE STANDARDS (GIPS®) AND HAS PREPARED AND PRESENTED THIS REPORT IN COMPLIANCE WITH THE GIPS STANDARDS. FOXHALL CAPITAL MANAGEMENT HAS BEEN INDEPENDENTLY VERIFIED FOR THE PERIODS 12/31/99 – 12/31/08 BY BEACON VERIFICATION SERVICES. The verification report is available upon request. Verification assesses whether (1) the firm has complied with all the composite construction requirements of the GIPS standards on a firm-wide basis and (2) the firm’s policies and procedures are designed to calculate and present performance in compliance with the GIPS standards. Verification does not ensure the accuracy of any specific composite presentation. PAST PERFORMANCE DOES NOT GUARANTEE FUTURE RESULTS.

FOXHALL CAPITAL MANAGEMENT, INC. | 35 Old Tavern Road | Orange, CT 06477
TEL: 203.891.8377, 800.416.2053 | FAX: 203.891.8382