BORTHWICK ASSOCIATES, INC.

NOTICE OF PRIVACY PROVISION

Pursuant to the provisions of the Gramm-Leach-Bliley Act of 1999 as well as requirements of the Securities & Exchange Commission, we hereby disclose our firm’s policy regarding the use of non-public financial and net worth information that you provide to us during the course of our business relationship. This disclosure is required by every provider of financial services including banks, insurance companies, brokerage firms, investment advisers and any other such institution required to collect and maintain financial information on your behalf.

Maintaining your privacy is of prime importance to us and the declarations so made in our policy are your assuredness that your personal information is kept secure. You have a right to know what personal information is being collected about you and how that information will be used. We collect non-public personal information about you from data you’ve provided to us on applications or otherrequired forms in the conduct of our business relationship. Such information includes name, address, tax identification number, date of birth, driver’s license number, employer and banking reference. With regards to that information, as well as any required updates or amendments to that information, we hereby state the following;

The information collected is only that which is required under federal and securities regulations.

All financial information that you provide to us is used for the sole purpose of opening and maintaining an investment advisory relationshipwith you.

No financial or net worth information will be disclosed to any financial institution, financial services organization or any individual, company or group organization that isnot required to conduct our business relationship with you, unless authorized by you in writing or required by federal subpoena. We may disclose information to select service operators that perform business operations for us such as custodians, brokers and statement providers, however these companies are prevented by legal agreement from using your information for their own purposes including marketing or selling this information to others.

Access to your information is restricted only to those who need to know that information in order to provide the services as agreed upon between Borthwick Associates and yourself. We maintain internal physical, administrative and technical safeguards to protect your non-public personal information from unauthorized access.Borthwick Associates and any of its representatives are not allowed in any way to divulge or disseminate any of your financial, personal or net worth information. Borthwick Associates conducts regular sessions to train employees on howbest to protect your information.

Any financial or net worth information used in internally generated computer reports is protected from unauthorized outside access (hackers) by firewalls believed to be sufficient. Borthwick Associates does not offer online access, secured or otherwise, to client information. In addition, Borthwick Associates refrains from and discourages sending any personal information by email.

If you close your account with us, we will continue to adhere to the privacy policies described above. All archived records are kept on the premises and then destroyed after mandatory storage periods.

This notice of privacy policy along with any required amendments or revisions will be provided to you annually. You do not need to take any action as a result of this notice. It is meant only to inform you of how we safeguard your non-public personal information. This notice is also available on our website at If you have any questions regarding this privacy policy, please write Meg Davidson at 745 McClintock Burr Ridge, IL 60527 or call her at 630-581-5627.

Reviewed 4/7/2014