BUSINESS CONTINUITY

PRIVACY STATEMENT

One of the most important components of our relationship with you is the trust that you have placed in us to keep your nonpublic information private.

The information you provide to Chartwell/CCS Transactions, LLC (“CCS”) is used for the purposes of advising and guiding you regarding certain investment transactions. The employees of CCS do not discuss client information with anyone outside the company unless specifically authorized to do so by you.

Information we collect and record about you is kept strictly confidential. We maintain security procedures and standards designed to protect nonpublic information at all times.

With the exception of circumstances where we are required by law to disclose your nonpublic information, we do not share such information with any unaffiliated entity. In the event that we change this policy and determine that it is beneficial to share information with an unaffiliated third party, we will notify you beforehand and give you the opportunity to opt-out of such information sharing.

BUSINESS CONTINUITY DISCLOSURE

CCS maintains a business continuity plan, which addresses interruptions to our normal course of business. This plan is reviewed annually and updated, as necessary. Our disclosure statement is available in written form upon request.

The plan outlines the actions CCS will take in the event of a single-building, citywide or regional business interruption, including the use of an office location not affected by the interruption, retrieval of off-site back up data, use of primary and alternate vendors for continued communication, notification of active clients to provide interim information and relocation of personnel to an unaffected site.

USA PATRIOT ACT IDENTITY VERIFICATION NOTICE

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who, or entity that, establishes an account. While there are exceptions to this requirement, we will ask for certain investor information such as legal name, legal address and/or principal place of business, state of incorporation, Taxpayer Identification number, Social Security number, date of birth, etc. that will allow us to demonstrate compliance with these regulations. In some cases, we may also ask for additional documents.

REQUIRED DISCLOSURE REGARDING SECURITIES INVESTOR PROTECTION CORPORATION (SIPC)

Although CCS does not maintain customer accounts or accept customer funds or securities, we are a member of SIPC. To obtain more information about SIPC, including a SIPC brochure, you may contact SIPC directly by telephone at (201) 371-8300 or refer to their web site at www.sipc.org.