INTRODUCTION

The Tegrit Privacy Policy (the "Policy") explains the manner in which Tegrit collects, utilizes and maintains non-public personal information about our clients, as required under Regulation S-P and certain state laws. This Policy only applies to non-public information of clients who are individuals and applies whether Tegrit manages the account directly or through the Tegrit Trust or other pooled vehicle, because Tegrit will collect non-public personal information about individual participants in the Tegrit Trust or other vehicle. Tegrit will treat these participants as its clients for purposes of this policy.

Regulation S-P prohibits the sharing of non-public personal information with any non-affiliated third parties unless the firm has provided notices of its privacy policies and an op-out notice for consumers or customers to opt-out of the disclosure of certain types of information.

In general, the privacy rules require that firms provide "clear and conspicuous" notices that reflect its privacy policies and procedures initially to a "consumer" and a "customer" at the time of establishing a customer relationship and annually during the relationship. A customer is one who has established a continuing relationship with the firm.

Regulation S-P does not apply to:

• A business or institutional customer;

• The sharing of information among affiliated entities; or

• Consumers, unless the firm intends to disclose a consumer's personal information to non-affiliated parties.

The initial and annual notices must be provided in writing, or electronically if a client consents, and must include the following:

• Categories of non-public personal information collected from and about clients;

• Categories of non-public information that the firm may disclose;

• Categories of such information about former clients that is disclosed and to whom it is disclosed;

• An explanation of the client's right to opt out of the disclosure of non-public personal information to certain non-affiliated third parties and the method by which this may be done; and

• The firm's policy and practice to protect the confidentiality, security, and integrity of non-public personal information.

Every employee must maintain such confidentiality of personal information and will affirm in writing their adherence to these principles of confidentiality and the Tegrit policies and procedures annually.

COLLECTION OF INFORMATION

"Personal information" is any information about a client that is obtained in connection with initiating or servicing an account. Tegrit collects personal information about its clients through the following sources:

1. Subscription, Trust, Investment Management documents or other contracts, investment questionnaires, and other information provided by the client in writing, in person, by telephone, electronically or by any other means.

2. The information can include:

          a. Name;

          b. Address;

          c. Nationality;

          d. Social Security Number;

          e. Financial and Investment Qualifications;

          f. Transactions with Tegrit either through a pooled investment vehicle or as a separately managed account;

          g. Bank Account Data; and

          h. Account Ownership and Value.

DISCLOSURE OF NON-PUBLIC PERSONAL INFORMATION

Tegrit does not sell or rent client information. Tegrit does not disclose non-public personal information about its clients to non-affiliated third parties or to affiliated entities, except as permitted by law. For example, Tegrit may share non-public personal information in the following situations:

1. To service providers in connection with the administration and servicing of the client or a pooled investment vehicle whereby the client is an investor and Tegrit is the investment adviser, which may include attorneys, accounts, auditors and other professionals. Tegrit may also share information in connection with the servicing or processing of client transactions or transactions of a pooled investment vehicle in which the client is an investor and Tegrit is the investment adviser.

2. To affiliated companies in order to provide the client with ongoing personal advice and assistance with respect to products and services purchased through Tegrit and to introduce the clients to other products or services that may be of value to the client.

3. To respond to a subpoena or court order, judicial process or regulatory authorities;

4. To protect against fraud, unauthorized transactions (such as money laundering), claims of other liabilities; and

5. Upon consent of a client to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the client.

Clients cannot opt out of information in categories 1-4 above. California clients can opt out of information arrangements with affiliates in category 2, when the information to be shared is "non-consumer report information" to be used for marketing purposes Consumer report information is information used to determine a consumer's eligibility for credit, insurance or employment.

Tegrit maintains safeguards to protect investor information. Tegrit restricts access to personal and account information of clients to those employees who need to know that information in the course of their job responsibilities. Access to client information by employees will be limited by the use of personal passwords assigned to those employees who have a business purpose to have access to the information. Tegrit will keep a list containing the names of those employees who have received password access and other relevant information and periodically monitor those employees' usal of client information

Tegrit's Policy applies to both current and former clients.

The Chief Compliance Officer will conduct an annual meeting whereby he or she will explain the current privacy policy and will update and inform employees of any changes that arise regarding federal regulations affecting this Policy or any changes that Tegrit may make to the Policy. This training will emphasize that personal and account information is for business use only, and will cover confidentiality, security of information, integrity of data, computer access and e-mails. Employees will be instructed to avoid sending or requesting e-mails containing non-public personal information and other confidential and sensitive data, except when necessary to provide proper service.

Response to Data Breaches

The SEC has proposed to amend Regulation S-P to require financial institutions to adopt policies and procedure to respond to data breaches, including notice to the SEC and the affected individuals. If the SEC adopts these amendments, this policy will be revised to reflect the new requirements.

In addition, about 40 states have laws requiring financial institutions to take certain actions in the event of a data breach. The definition of data breach and the types of notice required vary among the states.

If an employee suspects that client non-public personal information has been disclosed in violation of this policy, or a date breach has occurred, he or she should notify the Chief Compliance Officer immediately.