YOUR PRIVACY IS IMPORTANT TO ARM

In the course of serving you as an individual client or as someone associated with a corporate body or as an institutional client, ARM may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This Policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this Policy, the term "ARM" refers to Asset & Resource Management Company Limited, its subsidiaries and its affiliates.

THE SOURCES OF INFORMATION
The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to ARM during the course of your relationship with us. We may also collect information about your transactions and experiences with ARM relating to the products and services ARM provides. In addition, depending on the products or services you require, ARM may obtain additional information about you, such as your credit history, from consumer reporting agencies.

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g. recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.

OUR USE OF YOUR PERSONAL INFORMATION

We may use your personal information to:

• Administer, operate, facilitate and manage your relationship and/or account with ARM. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
• Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;
• Provide you with information (such as investment research), recommendations, or advice concerning products and services offered by ARM; and
• Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

DISCLOSURES OF YOUR PERSONAL INFORMATION WITHIN ARM
In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within ARM may be given, or given access to, your personal information. For example, one ARM entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services such as international brokerage, asset management and advisory and trust services. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within ARM is provided below, under Information Security: How We Protect Your Privacy.

DISCLOSURES OF YOUR PERSONAL INFORMATION TO THIRD PARTIES
ARM does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with ARM, including those that provide professional, legal or accounting advice to ARM. Non-affiliated companies that assist ARM in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that ARM dictates.

We may also disclose your personal information to fulfil your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.

You should know that ARM will not sell your personal information.

INFORMATION SECURITY: HOW WE PROTECT YOUR PRIVACY
ARM is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized ARM employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, our service providers are held to stringent standards of privacy. We also maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the other central features of our information security program are:

• A dedicated team - the Information Technology Unit - that designs, implements and provides oversight to our information security program;
• The use of specialized technology such as firewalls;
• Testing of the security and operability of products and services before they are introduced to the Internet, as well as ongoing scanning for publicly known vulnerabilities in technology;
• Internal and external reviews of our Internet sites and services;
• Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
• Implementing controls to identify, authenticate and authorize access to various systems or sites;
• Protecting information during transmission through various means;
• Providing ARM personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

OTHER PRIVACY POLICIES OR STATEMENTS; CHANGES TO POLICY
This Policy provides a general statement of the ways in which ARM protects your personal information. You may, however, in connection with specific products or services offered by ARM, be provided with privacy policies or statements that supplement this Policy. This Policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised Policy will be effective immediately upon posting to our Website.