NOTICE OF BATTENKILL CAPITAL, INC. PRIVACY POLICY

Our commitment to Your Privacy: Battenkill Capital, Inc. (Battenkill Capital) has a longstanding policy of protecting the confidentiality and security of information we collect about customers. We
will not share nonpublic information about you (Information) without your consent, except for
specific purposes described below. This notice describes the Information we may gather and the
circumstances under which we may share it.

Why We Collect and How We Use Information: We limit the collection and use of Information to the
minimum we require to deliver superior service to you. Such service includes maintaining your accounts with us, processing transactions requested by you and administering our business.

How We Gather Information: We get most Information directly from you, when you apply for,
access and use financial products and services offered by our firm. We may verify this information
or get additional information from consumer reporting agencies or public sources. This Information may relate to your finances, employment, as well as transactions and interactions with our firm or others.

How We Protect Information: Our employees are required to protect the confidentiality of Information and to comply with our established policies. They may access Information only when there is an appropriate reason to do so, such as to administer our products or services. We also maintain physical, electronic and procedural safeguards to protect Information, which comply with all applicable laws. Employees who violate our Privacy Policy are subject to disciplinary process.

Disclosure of Information: We may disclose any Information to or when we believe it necessary for the conduct of our business, or where law requires disclosure. For example, Information may be disclosed for audit or research purposes, to attorneys or other professionals, or to law enforcement and regulatory agencies, for example, to help prevent fraud. In addition, we may disclose Information to third party services providers (i) to enable them to provide business services for our firm, such as performing computer related data maintenance or processing services for our firm, (ii) to facilitate the processing of transactions requested by you, (iii), to assist us in offering products and services to you, or (iv) for credit review and reporting purposes. Except in those specific, limited situations, without your consent, we will not make any disclosures of Information to other companies who may want to sell their products or services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company. It is Battenkill Capital’s policy to require all third parties that are to receive any Information to sign strict confidentiality agreements.

Former Customers: Even if you are no longer a customer of our firm, our Privacy Policy will continue to apply.

Access to and Correction of Information: If you desire to review any file we may maintain for your personal Information, please contact us. If you notify us that any Information is incorrect, we will review it. If we agree, we will correct our records. If we do not agree, you may submit a short statement of dispute, which we will include in future disclosures of disputed Information. Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available.

Further Information: We reserve the right to change this Privacy Policy. The examples contained within this Privacy Policy are illustrations and they are not intended to be exclusive. This notice complies with a recently enacted Federal Law and new SEC regulations regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you.

Customer Identification Program Notice

Important Information You Need to Know About Opening A New Account

To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify, and record information that identifies each person who opens an account.

This Notice answers some questions about the firms Customer Identification Program.

What types of information will I need to provide?
When you open an account, we are required to collect information such as the following from you:

Your name
Date of birth
Address
Identification number:
U.S. Citizen: taxpayer identification number (social security number or employer identification number)
Non-U.S. Citizen: taxpayer identification number, passport number, and country of issuance, alien identification card number, or government-issued identification showing nationality, residence, and a photograph of you.

You may also need to show your drivers license or other identifying documents.

A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement, or trust agreement.

U.S. Department of the Treasury, Securities and Exchange Commission, FIRNA, and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience, objectives and risk tolerance.

What happens if I do nott provide the information requested or my identity cannot be verified?

We may not be able to open an account or carry out transactions for you. If we have already opened an account, we may have to close it.

We thank you for your patience and hope that you will support the financial industrys efforts to deny terrorists and money launderers access to Americas financial system.

Should you have any questions concerning our Customer Identification Program, you may submit a written request for additional information to our Customer Service Department located at 7252 Main Street, Manchester Center, VT 05255.