FIS Group

FIS Group is a registered investment adviser with the Securities and Exchange Commission under the Investment Advisers Act of 1940. Fiduciary Investment Solutions, Inc. and FIS Funds Management, Inc. are wholly-owned subsidiaries of FIS Group, Inc.

FIS Group believes that respecting and protecting your privacy is of the utmost importance, so although we are exempt from Regulation S-P as an institutional investment advisor, we have implemented the following Privacy Principles to affirm our continuing commitment to the proper use of client information.

1. We do not share non-public, information about our clients with outside companies or persons, unless it is for one of the following reasons: at the client’s direction; to provide a client with a service; or as otherwise permitted or required by law.

2. We may collect non-public information about you from the following:
a. Proposals, presentations, contracts, periodic reports and other documents containing your name, address, telephone number, tax identification number and e-mail address;
b. Information is retained on individuals who are institutional representatives of our clients, such as administrators, trustees, decision makers and staff advisors, as well as third party pension consultant contact information. None of this information is personal financial information; rather, it is routine client relationship information.

3. Individual participants in, or beneficiaries of, our clients’ pension funds are not shared with outside companies or persons.

4. We may disclose our client list to the public, including the type of services FIS Group renders, length of the client relationship and the assets under management, for marketing purposes only, unless such disclosure is prohibited by a client.

5. Except as otherwise provided herein, information relating to a financial service that is specific to an institutional client is available only to that client and its designees.

6. We maintain physical, electronic, and procedural safeguards to protect non-public
information we obtain about our clients.

7. Non-public information of former clients is protected to the same extent as that of our current clients.

8. We require that all employees adhere to our Privacy Principles.