Statement from Singapore To: Unaico Limited We refer to your email dated 28 September 2010.

As per request, please find below a statement that addresses the questions in your email dated 28 September 2010: 1. Does the Unaico compensation plan contravene against local law, does it indicate a prohibited snowball scheme or not? The Unaico compensation plan would constitute “a multi-level marketing and pyramid selling scheme” but would not contravene the Multi-level Marketing and Pyramid Selling (Prohibition) (Amendment) Act provided that the conditions under the Multi-level Marketing and Pyramid Selling (Excluded Schemes and Arrangements) (Amendment) Order 2001 are complied with. 2. Does the transmission of options to Unaico-Distributors contravene local stockcorporation and trade law? Section 240 (1) of the Securities and Futures Act (“SFA”) provides that no person shall make an offer of securities unless the offer is made in or accompanied by a prospectus in respect of the offer and complies with such requirements as may be prescribed by the authorities. As far as Unaico Ltd is concerned, Section 272(1) SFA will exempt Unaico Ltd from the requirements of Section 240 (1) SFA on the basis that the OFCs are offered to Unaico Members at no cost. 3. Does the money transfer between Unaico Distributors contravene local commercial law? Pursuant to the Payment Systems (Oversight) Act (Cap. 222A) (“PSA”), the E-Wallet and Mandatory Account could be regarded as a payment system and stored value facilities. In this regard, please ensure that: (a) (b) the Company does not hold itself as a holder that is approved by the Monetary Authority of Singapore under Section 35(1) PSA of the E-Wallet and Mandatory Account; the stored value of the E-Wallet or Mandatory Account does not exceed S$30 million unless the approval of the MAS is obtained for the continued operation of such facilities or such facilities may only be used for the payment of goods and/or services (as provided under the Payment Systems (Oversight) (Exclusion of Single Purpose Stored Value Facilities) Order 2006); the terms and conditions of the E-Wallet and Mandatory Account complies with Regulation 12 of The Payment Systems (Oversight) Regulations; and the Stored Value Facility Guidelines and Notice to Holders of Stored Value Facilities (last revised on 2 December 2009) is complied with.

(c) (d)

Please refer to our legal opinion dated [●] which sets out our advice on these issues.

Law Firm

Singapore

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