OM Investment-Privacy Policy

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PRIVACY POLICY

OM Investment Management is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Statement of Privacy applies to the OM Investment Management website and governs data collection and usage. By using the OM Investment Management website, you consent to the data practices described in this statement.

Your relationship with OM Investment Management is based on trust and confidence. OM Investment Management depends on you for current and accurate financial and personal information. You deserve and expect that OM Investment Management will protect the information you have provided in a manner that is safe, secure and professional. OM Investment Management and its employees are committed to protecting your privacy and to safeguarding your information.

SAFEGUARDING CUSTOMER DOCUMENTS

During regular business hours access to customer records is monitored so that only those with approval may access the files. During hours in which the company is not in operation, the offices are locked.

No unauthorized person shall obtain personal and financial customer information. No authorized individual shall share that information in any manner without the specific consent of a firm principal. Failure to observe OM Investment Management procedures regarding customer and consumer privacy will result in discipline and may lead to termination.

SHARING NONPUBLIC PERSONAL AND FINANCIAL INFORMATION

OM Investment Management is committed to the protection and privacy of its customers and consumers personal and financial information. OM Investment Management will not share such information with any nonaffiliated third party except:

• When necessary to complete a transaction in the account, such as with the clearing firm or account custodians

• When required to maintain or service the account

• To resolve customer disputes

• When requested by a fiduciary or beneficiary on the account

• To rating agencies rating, or to the client’s attorneys or accountants

• When required by a regulatory agency, or for other reasons required or permitted by law

• In connection with a sale or merger of OM Investment Management business

• In any circumstance that has the customer’s instruction or consent.

OPT-OUT PROVISION

It is not a policy of OM Investment Management to share nonpublic personal and financial information with unaffiliated third parties except under the circumstances noted above. Since sharing under the circumstances noted is necessary to service the client account or mandated by competent authority there are no allowances made for clients to opt out.

CHANGES TO THIS STATEMENT

OM Investment Management will occasionally update this Statement of Privacy to reflect company and customer feedback. OM Investment Management encourages you to periodically review this Statement to be informed of how OM Investment Management is protecting your information.

CONTACT INFORMATION

OM Investment Management welcomes your comments regarding this Privacy Statement. If you believe that OM Investment Management has not adhered to this Statement, please contact OM Investment Management at info@omimllc.com. We will use reasonable efforts to promptly determine and remedy the problem.