CUSTOMER PRIVACY POLICY

Barrington Research Associates, Inc. (“Barrington”) has a long-standing commitment of protecting the confidentiality and security of information we collect from our clients. It is our policy that we do not share nonpublic information about you outside of Barrington Research without your consent except for the specific purposes described below, in accordance with all applicable laws. The following describes the information we may gather and the circumstances under which it may be disclosed.

Collection of Information

In conducting our business and providing our clients with products and services, we collect nonpublic personal information (“Information”) about our clients. This Information includes information we receive from you on applications or other forms; information about your transactions with us, our affiliates, or others; information we receive from nonaffiliated third parties (e.g. consumer reporting agencies); and information obtained through the use of our website.

Disclosure of Information

We do not disclose Information about our clients or former clients to any nonaffiliated third parties, except as permitted by applicable law or regulation. We may share Information with affiliates of Barrington, as well as with nonaffiliated companies that perform various services such as transfer agents, custodians, broker/dealers and other service firms and financial institutions with whom we have relationships. One service provider relationship, which we maintain in particular, is with J.P. Morgan Clearing Corp. J.P. Morgan Clearing Corp. clears all of Barrington’s transactions on behalf of our clients. We may also share Information with nonaffiliated companies with which we have joint marketing agreements, such as an agreement with another broker/dealer or registered investment adviser enabling us to offer you certain of its products or services.

Protection of Information

All employees are required to protect the confidentiality of Information and to comply with our established policies. We restrict access to Information about you to those employees who need to know that Information to provide products or services to you. We maintain physical, electronic, and procedural safeguards, within the applicable laws, to guard your Information.

Affiliates of Barrington Research Associates, Inc.

The following companies are under common control with Barrington Research Associates, Inc.:

Barrington Asset Management, Inc.
HMR Publishing Company, Inc.

Further Information

For questions concerning Barrington’s Privacy Policy, write us at Barrington Research Associates, Inc., Attn: Compliance Department, 161 N. Clark Street, Suite 2950, Chicago, Illinois 60601, or telephone Gregory Paris at (312) 634-6000. We reserve the right to change this Privacy Policy at any time.