The Benefit Trust Company has a long standing policy of treating our client's personal information as confidential and we are committed to maintaining the highest level of confidentiality in regard to all personal information we collect regarding our clients.

Today, data can be stored and transmitted in ways we never would have imagined when our company was founded. But technology, even with all its amazing capabilities, does not change our commitment or our responsibility to you, our client. We value our relationships highly and protect them in every way that we can. This protection begins with our treatment of the personal information you have chosen to share with us. We believe that you have the right to understand the information we collect from you and how we protect that information.

"Nonpublic personal information" is information that we obtain from you in the course of acting as your trustee, investment advisor or custodian. Examples of this type of information include:

• Personal information such as name, address, phone number, date of birth and social security numbers.
• Financial information such as income, net worth, risk tolerance, account numbers, tax bracket, assets and liabilities.
• Personal family information such as names, addresses and dates of birth of family members.

We might collect nonpublic personal information about you from several sources:

• Directly from you through meetings and phone calls.
• From information supplied through account agreements and other forms.
• From nonaffiliated third parties such as your accountant, attorney or other professionals.
• From members of your family.
• From information received directly from affiliated third parties.

Please note that we will not share any of your personal information with your attorney, accountant, other industry professionals or family members without your prior permission.

We use your personal information in ways that help us provide our services to you. For example, we will use information we have about you to process your requests and transactions, to provide you with additional information about our services or services of an affiliate, or to evaluate your financial needs. We may also use your information in ways that help us administer our business.

To do this, we may share your information with:

• Individuals with whom you have directed us to speak (such as your accountant, your attorney or family members).
• Regulators such as state trust examiners when we are required to disclose your information by law.
• Accountants and auditors hired by our Company that perform tax work and required annual examinations.
• An affiliate with whom we have contracted for operational or investment management services.
• Consultants that we may hire from time to time to review our business and regulatory practices.
• Nonaffiliated third parties that provide performance measurement services.

We do not sell personal information to anyone. We will not disclose any of your personally identifiable information to nonaffiliated third parties other then the above unless we have your permission. Individuals or companies that we may hire to provide additional services are required to conform to our privacy standards. If you prefer that we not disclose nonpublic personal information about you to nonaffiliated third parties, you may opt out of those disclosures, that is, you may direct us not make those disclosures (other than disclosures permitted by law). If you wish to opt out of disclosures to nonaffiliated parties, you may call the following toll free number : 888-696-0100.

We will oftentimes communicate with you using email. In order to protect your privacy while still allowing us to easily communicate with you, we have implemented encrypted e-mail. Encrypted e-mail contains special coding that prevents outside sources from accessing your private information. Our system automatically detects which e-mails need to be encrypted.

All Benefit Trust Company employees are bound by policies that include the responsibility to protect the confidentiality of client information. Only those employees who need nonpublic personal information about clients to do their jobs are given access to this information. We maintain physical, electronic and procedural safeguards (such as passwords, locked files and electronic firewalls) to guard your nonpublic personal information.

We will continue to evaluate our efforts to protect your personal information and ensure that it is kept accurate and current. If you find any error in your personal information, need to make a change to that information, or have any questions about our policies, please contact us.

We reserve the right to change or update our policies. If we do so, however, we will first notify you in writing. We never provide any confidential information to anyone other than those listed above without first giving you the opportunity to say no.