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Independence and objectivity has not been violated. According to Standard III(B), allocation of new issues according to advance indications of interest should be done on a pro-rata basis by client, rather than by portfolio manager. Therefore, Horizon’s policy is not fair and equitable. Disclosure of this inequitable allocation method does not relieve Horizon of its obligation that the allocation method be fair and equitable. While the policy may violate fiduciary duty as required by Standard III(A), it does not violate either Standard III(C), which addresses investment suitability, or Standard VI(B), which relates to the priority of transactions