Disclosures

USER AGREEMENT

All of the information on this web site is copyrighted material of Barrington Research Associates (“Barrington Research”). You agree not to reproduce, distribute or transfer any data or reports found at this web site, or create any hypertext links into this web site, without prior written permission from Barrington Research.

The information contained herein has been obtained from sources believed to be reliable, however, Barrington makes no representation or guarantee as to its accuracy or completeness. Any opinions or estimates expressed herein reflect Barrington’s judgement as of the date of issue of the relevant information and are subject to change without notice.

The information on this web site is for informational purposes only and should not be construed as a solicitation to purchase or sell securities or endorsement of any particular trading strategy. Barrington makes no determination of the suitability of any investment for any particular user.

Barrington and its directors, officers, employees, representatives, agents, affiliates or associated persons (“Associated Persons”) specifically disclaim, to the full extent permitted by law, any liability for errors, inaccuracies or omissions on this web site and any loss or damage resulting from its use, whether caused by negligence or otherwise.

Barrington and its Associated Persons may have an interest in the securities of the companies mentioned herein and may buy or sell such securities as principal or agent.

Barrington may perform investment banking services for some companies described herein and may occasionally possess material, nonpublic information regarding such companies. Such information is not used in the preparation of the opinions and estimates herein.

THE WEB SITE AND ANY INFORMATION PROVIDED THEREIN IS BEING PROVIDED “AS IS”, “AS AVAILABLE” AND WITHOUT ANY WARRANTY OF ANY KIND, EITHER EXPRESSED OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTIBILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT.

CUSTOMER PRIVACY POLICY

Barrington Research Associates, Inc. (“Barrington”) has a long-standing commitment of protecting the confidentiality and security of information we collect from our clients. It is our policy that we do not share nonpublic information about you outside of Barrington Research without your consent except for the specific purposes described below, in accordance with all applicable laws. The following describes the information we may gather and the circumstances under which it may be disclosed.

Collection of Information

In conducting our business and providing our clients with products and services, we collect nonpublic personal information (“Information”) about our clients. This Information includes information we receive from you on applications or other forms; information about your transactions with us, our affiliates, or others; information we receive from nonaffiliated third parties (e.g. consumer reporting agencies); and information obtained through the use of our website.

Disclosure of Information

We do not disclose Information about our clients or former clients to any nonaffiliated third parties, except as permitted by applicable law or regulation. We may share Information with affiliates of Barrington, as well as with nonaffiliated companies that perform various services such as transfer agents, custodians, broker/dealers and other service firms and financial institutions with whom we have relationships. One service provider relationship, which we maintain in particular, is with Wedbush Securities Inc. clears all of Barrington’s transactions on behalf of our clients. We may also share Information with nonaffiliated companies with which we have joint marketing agreements, such as an agreement with another broker/dealer or registered investment adviser enabling us to offer you certain of its products or services.

Protection of Information

All employees are required to protect the confidentiality of Information and to comply with our established policies. We restrict access to Information about you to those employees who need to know that Information to provide products or services to you. We maintain physical, electronic, and procedural safeguards, within the applicable laws, to guard your Information.

Affiliates of Barrington Research Associates, Inc.

The following companies are under common control with Barrington Research Associates, Inc.:

• Barrington Asset Management, Inc.
• Barrington Opportunity Fund Management, LLC

Further Information

For questions concerning Barrington’s Privacy Policy, write us at Barrington Research Associates, Inc., Attn: Compliance Department, 161 N. Clark Street, Suite 2950, Chicago, Illinois 60601, or telephone (312) 634-6000. We reserve the right to change this Privacy Policy at any time.

CUSTOMER IDENTIFICATION PROGRAM NOTICE

IMPORTANT INFORMATION ABOUT PROCEDURES
FOR OPENING A NEW ACCOUNT

To help the government fight the funding of terrorism and money laundering activities, all financial institutions are required by law to obtain, verify and record information that identifies each individual or entity that opens an account.

When you open an account, we will ask you for certain information, such as: your name, address, taxpayer or other government identification number and, in the case of an individual, your date of birth. We may also ask to see identification documents such as a driver’s license or passport, and in the case of an entity, documents showing the existence of such entity.

U.S. Department of the Treasury, Securities and Exchange Commission, FINRA, 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 and objectives, and risk tolerance.

If you don’t provide the information requested or your identity can’t be verified, we may not be able to open an account or carry out transactions for you.

We thank you for your patience and hope that you will support the financial industry’s efforts to deny terrorists and money launderers access to America’s financial system.

BUSINESS CONTINUITY PLAN SUMMARY

Barrington Research Associates, Inc., (“Barrington”) is committed to safeguarding the interests of our customers, the safety of our employees and the protection of firm property in the event of an emergency or significant business disruption (“SBD”). To this end, Barrington has established a Business Continuity Plan (“BCP”) outlining procedures and back-up systems aimed at mitigating the risks inherent with unforeseen business interruptions and to quickly recover and resume operations.

The BCP is intended to comply with the rules promulgated by the Securities Exchange Commission and the Financial Industry Regulatory Authority and covers areas such as: back-up and recovery of customer and business records; identification and backup of all mission-critical systems; financial and operational risk assessments; alternate communication between Barrington its clients, employees and regulators; alternate physical locations; assessment of critical business constituent, bank and counter-party impacts; regulatory reporting; and client access to their funds and securities. Barrington’s BCP is tested regularly and reviewed annually.

There is a broad range of scenarios under which a SBD might occur. They can be generally categorized as internal or external. Internal SBD’s include those business disruptions that affect only our firm’s ability to communicate and do business, such as a fire or power failure in our building. External SBD’s affect the operation of the securities markets or a number of firms, such as a terrorist attack, city flood, or a wide-scale, regional disruption.

Barrington conducts all of its business at its primary facility located at 161 N. Clark St., Chicago, Illinois. Protecting the infrastructure of our primary facility is a high priority because it will allow the firm to continue operations in the event of many disaster situations by permitting our employees to have access to and use of our facilities during that situation. Our primary facility is equipped with physical security measures, fire suppression systems and battery back-ups. Critical computers systems are backed up on a regular basis.

Should we encounter an internal SBD that prevents the use of our primary business facility, our goal is to relocate key personnel and forward telecommunications to our alternate site and resume business activities within 24 hours. The alternative facility is a “hot site.” In other words, the site is fully operational at all times. It is equipped with workstations that have redundant computer network connectivity, telephones, printers, fax machines, market data feeds and all other specialty equipment necessary for trading and operations. The backup trading positions are periodically checked to ensure that they are equipped with updated software and trading applications. The functionality of the backup facility is routinely tested by sales, trading and operations personnel.

Should a larger scale external SBD occur, it is our goal to resume business activities as soon as practical given the specific circumstances surrounding the SBD. Such an SBD may or may not require a relocation of operations to the alternate site. In any case, our goal remains to continue our business and protect the assets of our customers to the best of our abilities.

During any SBD, communication with employees, customers and other key business parties is of vital importance. We use a combination of general broadcast and direct-contact methods. General information such as office closures, operating hours and alternative contact information will be posted on the firm’s website. Barrington has developed an emergency contact list providing multiple points of contact for each department manager, as well as formal protocols to assist in avoiding confusion and to effectively resume business. Should you not be able to contact your salesperson, please call (800) 233-6205.

In its business, Barrington relies on a number of critical third-party providers. These providers have business continuity plans, including systems redundancies and backup locations. The most significant third-party provider is our clearing firm Wedbush Securities Inc. (“Wedbush”). Barrington relies on Wedbush to maintain customer account records, execute transactions, custody client assets and provide certain operating systems. In the case of SBD where customers are not able to contact Barrington, you should contact our clearing firm, Wedbush at 213-688-4400. , or www.wedbush.com for liquidating orders, check and wire requests and ACAT transfers.

In conclusion, Barrington’s BCP addresses the steps the firms will take to address a temporary business disruption in a systematic and organized fashion. Of course, the effects of a disaster are difficult to predict and the disruption of systems and processes on an industry wide basis will pose great challenges to any business continuity plan. There can be no assurance that any plan can address such unforeseen contingencies. The BCP and this summary may be changed without notice. In the event of a modification, an updated summary will be posted to our website. Alternatively, customers may obtain an updated summary by requesting a written copy by mail.