Policy Statement
Oppenheimer Capital (referred to as "the Firm") considers customer privacy to be a fundamental aspect of its relationship with clients and is committed to maintaining the confidentiality, integrity and security of its current, prospective and former clients’ personal information. To ensure client’s privacy, the Firm has developed policies that are designed to protect this confidentiality, while allowing client needs to be served.

Obtaining Personal Information
In the course of providing clients with products and services, the Firm may obtain nonpublic personal information about clients which may come from sources such as account applications and other forms, from other written, electronic or verbal correspondence, from client transactions, from a client’s brokerage or financial advisory firm, financial adviser or consultant, and/or from information captured on its internet web sites.

Respecting Your Privacy
As a matter of policy, the Firm does not disclose any personal or account information provided by clients or gathered by us to non-affiliated third parties, except as required or permitted by law. As is common in the industry, non-affiliated companies may from time to time be used to provide certain services, such as preparing and mailing prospectuses, reports, account statements and other information, conducting research on client satisfaction and gathering shareholder proxies. The Firm may also retain non-affiliated companies to market its products and enter in joint marketing agreements with other companies. These companies may have access to a client’s personal and account information, but are solely permitted to use this information to provide the specific service or as otherwise permitted by law. The Firm may also provide a client’s personal and account information to their respective brokerage or financial advisory firm, Custodian, and/or to their financial adviser or consultant.

Sharing Information with Third Parties
The Firm reserves the right to disclose or report personal information to non-affiliated third parties, in limited circumstances, where the Firm believes in good faith that disclosure is required under law to cooperate with regulators or law enforcement authorities, to protect its rights or property or upon reasonable request by any mutual fund in which a client has chosen to invest. In addition, the Firm may disclose information about a client or a client’s accounts to a non-affiliated third party only if the Firm receives a client’s written request or consent.

Sharing Information with Affiliates
The Firm may share client information with its affiliates in connection with servicing a client’s account or to provide a client with information about products and services that the Firm believes may be of interest to them. The information the Firm shares may include, for example, a client’s participation in its mutual funds or other investment programs, a client’s ownership of certain types of accounts (such as IRAs), or other data about a client’s accounts. The Firm’s affiliates, in turn, are not permitted to share client information with non-affiliated entities, except as required or permitted by law.

Procedures to Safeguard Private Information
The Firm takes seriously its obligation to safeguard client non-public personal Information. In addition, the Firm has physical, electronic, and procedural safeguards in place to guard a client’s non-public personal information. The Firm will dispose of records that are knowingly derived from data received from a consumer reporting agency regarding an Advisory Client that is an individual in a manner that ensures the confidentiality of the data is maintained.