APERIO GROUP PRIVACY POLICY

In accordance with the privacy requirements of SEC Regulation S-P, we are pleased to provide clients with the following information about how we handle confidential information.

Our clients provide us with information that is inherently personal and private in nature, and we want them to know that we take seriously our duty to maintain the confidential nature of that information. It is our policy not to disclose any non-public personal information about our current or former clients to anyone except when doing so is required by law or our client authorizes us to do so.

We collect nonpublic information about our clients from the following sources:

• Information about transactions with us and others;
• Information we receive from clients in written agreements and on applications and other forms; and
• Information we receive from clients verbally in the regular course of providing services.

We may disclose nonpublic personal information about clients to the following types of nonaffiliated parties as necessary to provide our services:

• Financial service providers, such as asset custodians, mortgage lenders, banking institutions, and insurance agents;
• Regulatory and Governmental Authority as required by applicable law;
• Professional service providers, such as attorneys, accountants, and real estate brokers; and
• Others, as the client may specify or request.

We take the utmost care in addressing the administrative, technical, and physical safeguards for the protection of client records and information. For example:

• On-site records storage is consistently monitored during business hours to preclude any third party access; and
• We maintain all other necessary physical, electronic, and procedural safeguards in compliance with federal standards to guard our clients' nonpublic personal information.

If you have any questions regarding these policies and procedures, please contact us.