Fiduciary Asset Management Privacy Policy

In accordance with Regulation S-P, a rule adopted by the Securities and Exchange Commission, Investment Managers are required to disclose their privacy policies to their clients. Fiduciary Asset Management's privacy policy is as follows:

1. We do not sell your personal information to anyone, nor do we use your name in marketing presentations unless specifically approved by you.

2. We collect the following types of personal information about you in order to provide our investment advisory services to you:

• Application information and other forms. We collect information you supply on applications and other forms such as your name, address, social security number, age, financial status, assets, income, investment objectives, information that we collect on our web site through the use of “cookies” and other personal information. We may also collect such information through your inquiries by mail, E-mail or telephone.
  
  
• Transaction information. Once you become a client, to better understand your financial situation toward our goal of providing better services to you, you may provide information about your transactions with portfolios or assets managed by other investment advisers. In such cases we will treat the information with the same level of confidentiality as with the assets we manage.

3. We do not disclose personal information to third parties, unless one of the following limited exceptions applies:

• We disclose specific personal information to a third party if we receive written direction from you to do so.
  
  
• In order to service your account and effect transactions, we disclose your personal information to only those unaffiliated companies that perform administrative services on behalf of the account, such as bank trustees or broker-dealers acting as custodians for your account.
  
  
• We may disclose or report personal information in limited circumstances only as required or permitted under law, for example, to cooperate with regulators or law enforcement authorities, to our legal and accounting professionals, and to our software vendors who provide technical support necessary to safeguard the integrity of our systems and to assist us in providing better services to you.
  
  
• When disclosing information to third parties, we disclose only the minimum amount of information required to satisfy the specific service we have requested.

4. We protect the confidentiality and security of your personal information.

• We only disclose information to parties who provide necessary services to us and who are contractually obligated to maintain strict confidentiality of your account information.
  
  
• We restrict access to personal information about you to only those employees who need to know that information to provide our services to you.
  
  
• We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your personal information.
  
  
• We take seriously the obligation to protect against unauthorized access to or use of your personal information in connection with its disposal.

5. We continue to protect the privacy of former customers.

• Even if you are no longer our customer, our privacy policy will apply to you.