March 2013

We consider customer privacy to be a fundamental aspect of our relationship with clients. We are committed to maintaining the confidentiality, integrity, and security of our current, prospective and former clients' personal information. We have developed policies that are designed to protect this confidentiality, while allowing client needs to be served.

In the course of providing you with products and services, we and certain of our service providers may obtain non-public personal information about you. This information may come from sources such as account applications and other forms, from other written, electronic or verbal correspondence, from your transactions, from your brokerage or financial advisory firm, financial adviser or consultant, and/or from information captured on our internet websites.

As a matter of policy, we do not disclose any personal or account information provided by you or gathered by us to non-affiliated third parties, except as required or permitted by law or for our everyday business purposes, such as to process transactions or service your account. As is common in the industry, non-affiliated companies may from time to time be used to provide certain services, such as preparing and mailing prospectuses, reports, account statements and other information, conducting research on client satisfaction, and gathering shareholder proxies. We may also retain non-affiliated financial service providers, such as broker-dealers, to market our products, and we may enter into joint marketing arrangements with them and other companies. These companies may have access to your personal and account information, but are permitted to use the information solely to provide the specific service or as otherwise permitted by law. We may also provide your personal and account information to your brokerage or financial advisory firm and/or to your financial adviser or consultant.

We reserve the right to disclose or report personal information to non-affiliated third parties in limited circumstances where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities, to protect our rights or property, or upon reasonable request by any of our mutual funds in which you have invested. In addition, we may disclose information about you or your accounts to a non-affiliated third party at your request or if you consent in writing to the disclosure.

We may share client information with our affiliates in connection with servicing your account, and subject to applicable law may provide you with information about products and services that we or our affiliates believe may be of interest to you. The information that we may share may include, for example, information about our or our mutual funds' experiences and transactions with you, your participation in our mutual funds or other investment programs, your ownership of certain types of accounts (such as IRAs), information captured on our internet websites, or other data about your accounts, subject to applicable law. Our affiliates, in turn, are not permitted to share your information with non-affiliated entities, except as required or permitted by law.

We take seriously the obligation to safeguard your non-public personal information. In addition to this policy, we have implemented procedures that are designed to restrict access to your non-public personal information to our personnel who need to know that information to perform their jobs, such as servicing your account or notifying you of new products and services.  Physical, electronic, and procedural safeguards are in place to guard your non-public personal information.

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