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This Fund never  reveals information about its shareholders, except at the request of a shareholder or government requirements. For example, if the shareholder is applying for a mortgage and lists their assets and then requests it, an account confirmation is sent to the lending institution.

The Fund will comply with giving information as may be required by law. An example is a subpoena from a court or other proper government agency. Tax information is disclosed as required by law to the tax authorities. The Fund also has an anti-money laundering program which requires responding to inquiries from government authorities.

The Fund uses an outside transfer agent who keeps shareholder records. The transfer agent is the Fund representative and will be instructed to carry out the Fund policy.

The Fund and its manager has no relationship with any bank, insurance company or brokerage house, except the brokerage houses with which it buys and sells shares and the brokerage houses which sells fund shares. No personal information is given by the Fund to any of these entities.


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