Privacy Statement

At Richmond Capital Management, protecting the confidentiality and security of our clients’ information has always been an important part of the way we conduct our business.  We want you to know that we are committed to safeguarding your privacy while helping you achieve your investment objectives.  This letter outlines Richmond Capital Management’s Privacy Policy, which we are required by federal law to send annually to all individual customers.

Richmond Capital Management is committed to keeping the information you provide secure and confidential.  All of the nonpublic personal information we collect and retain about our clients is solely for the purpose of managing the investment accounts.  Such information would include information provided in the client investment contracts, client investment policy statements, and transactions within the accounts.

Richmond Capital Management does not disclose nonpublic personal information about you to anyone without your permission except as required by law.  Our policy applies to both former and current clients.

Keeping financial information secure is one of our most important responsibilities.  Our customers’ privacy is of critical importance and Richmond Capital Management uses strict security standards to safeguard it.  We maintain physical, electronic, and procedural safeguards to guard your nonpublic personal information and we continually assess new technology for protecting information.  Access to customer information is limited to those associates who need to know that information in order to provide, maintain, or service our products.  In addition, all Richmond Capital Management associates are governed by the Code of Ethics and Standards of Professional Conduct of the CFA Institute, which includes the responsibility to protect the confidentiality of customers’ financial and personal information.

At Richmond Capital Management we strive to maintain the accuracy of your information.  If we become aware of inaccuracies in our records, we will take prompt steps to make the appropriate corrections.  If you would like to correct, update, or confirm your information, please do not hesitate to call Betsy Harris, Managing Director, Client Services, at (804) 379-8282.   We will be happy to review our records with you.  Maintaining your privacy is important to Richmond Capital Management, and we appreciate the trust and confidence you have placed in us.

Sincerely,

Howard K. Bos

President

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