PRIVACY POLICY

Minneapolis Portfolio Management Group, LLC (“MPMG”) has adopted the following privacy policy in order to safeguard the nonpublic personal information of MPMG’s clients in accordance with applicable law:

(1)          MPMG is committed to protecting the confidentiality and security of the information it collects and will handle nonpublic personal information about clients only in accordance with all applicable laws, rules and regulations.  MPMG will seek to ensure: (a) the security and confidentiality of client records and information; (b) that client records and information are protected from any anticipated threats and hazards; and (c) that unauthorized access to, or use of, client records or information is protected against.

(2)          MPMG will maintain policies and procedures that are reasonably designed to safeguard nonpublic personal information about clients and only permit appropriate and authorized access to, and use of, nonpublic personal information about clients through the application of appropriate administrative, technical and physical protections.

(3)          MPMG will not disclose any nonpublic personal information about its clients or former clients to anyone, except as permitted or required by law.

(4)          MPMG will issue notices of its privacy policy to its clients initially and on an annual basis thereafter to the extent required by applicable law or contractual provisions, whichever is more restrictive.

Subject to the exceptions noted below, MPMG will not divulge to third parties nonpublic personal information, including its portfolio holdings, specific trading strategies or pending transactions.  MPMG will also take suitable security measures, including maintaining client files in locked drawers and requiring passwords to access systems containing client data.

MPMG may disclose portfolio holdings, specific trading strategies, pending transactions or other information not generally available to the public to those service providers of MPMG who need such information in the normal course to provide their services.

MPMG will require that any such service providers acknowledge their duties of confidentiality and care with respect to nonpublic personal information concerning MPMG’s clients, represent that they have taken reasonable steps to safeguard such information, and represent that no service provider employee or other representative who possesses such information about MPMG will transact in any securities or other instruments based on, or otherwise misuse or pass along, such information.

In all other cases, MPMG may be permitted to disclose portfolio holdings, specific trading strategies, pending transactions or other information not generally available to the public.  Generally, employees should discuss any such disclosure and obtain advance approval from MPMG’s Chief Compliance Officer.