CARTER CAPITAL MANAGEMENT considers client privacy to be a fundamental aspect of our client relationships. We are committed to maintaining the confidentiality, integrity, and security of our current, prospective and former clients’ personal information.

In the course of providing you with advisory services, we may collect, retain, and use client information for the purpose of administering our operations, providing client service, and complying with legal and regulatory requirements. This information may come from sources such as account applications, investment policy statements, from your transactions, and other forms from other written, electronic or verbal correspondence from your brokerage, attorney, accountant or other advisor you may employ. We do not sell, exchange or disclose client information with outside organizations unless the third party is essential in administering our operations or except as required or permitted by law.

No confidential information, whatever the source, regarding any customer or client, may be disclosed except the following: We reserve the right to disclose or report personal information where we believe in good faith that disclosure is required under law, to cooperate with regulators or law enforcement authorities. Adviser reserves the right to disclose information with other Adviser employees in connection with the Adviser’s business and to non-affiliated third parties with whom the Adviser has a contractual agreement to jointly offer, endorse or sponsor a financial product or service; and to service and maintain customer accounts including effectuating a transaction. Adviser may disclose information about client or client’s account to a non-affiliated third party at client’s written request.

Lastly, to further safeguard client information digitally, we maintain password protected systems, updated anti-virus and anti-spyware software, and encrypted hardware and software firewalls.

Securities laws impose substantial responsibilities and penalties on investment advisors in connection with insider trading. “Inside information” is material, non-public information. It includes information, which in reasonable and objective contemplation might affect the value of a corporation’s stock or securities, or information, which, if known, would clearly affect ‘investment judgment’, or which directly, bears on the intrinsic value of a company’s stock.

CARTER CAPITAL MANAGEMENT employees and representatives are strictly prohibited from gaining profit, avoiding loss, or otherwise misusing or directly or indirectly benefiting financially or otherwise from any material, non-public information. Prohibited activities relating to insider trading include but are not necessarily limited to the following:

1) Trading in any account, individual account, or discretionary account in a security, option, bond or warrant while in possession of important non-public information, such as, but not limited to advanced knowledge of a tender offer or underwriting or block transfer.

2) Providing any important non-public information to any client, relative, associate or any other individual whom then trades in securities or otherwise directly or indirectly benefits from such information.

3) Sharing or otherwise having an interest in any account establishing a fictitious or nominee account for the purpose of concealing such interest in an account that gains a profit, avoids a loss, or otherwise directly or indirectly benefits, financially or otherwise, from material, non-public information.

4) Engaging in any other device, scheme or contrivance to directly or indirectly benefit, financially or otherwise, from important non-public information.

Any supervised person proven to be involved in insider trading is subject to immediate dismissal. Furthermore, individuals found to be guilty of insider trading are subject to penalties provided by law which may include civil injunctions, disgorgement of profits, jail sentences, fines of up to three times the profit gained or loss avoided, fines for the employer or other controlling person of the person who committed the violation.

Any "access person" (i.e. supervised person that has access to nonpublic information regarding recommendations to clients on the purchase or sale of securities, clients' trading information or nonpublic information regarding a portfolio holding of an affiliated mutual fund, or involved in providing investment advice to clients) shall upon receipt of this information complete and submit a Personal Securities Transaction report within 10 days and annually thereafter. This information must be current as of the date the individual becomes an access person or, for an annual report, the date the report is submitted. Access persons must report their personal trading activities, if any, quarterly to the adviser's Chief Compliance Officer within 30 days after the close of the quarter. All advisers must gain pre-approval in any initial public offering or private placement. Any violation of the code shall be reported to the Chief Compliance Officer.

CARTER CAPITAL MANAGEMENT Form ADV Part II Disclosure