Compliance Statement

Privacy Policy

Maintaining the confidentiality of client personal financial information is very important to Paladin.

To provide clients with superior service, Paladin may collect several types of nonpublic personal information about clients, including:

  • Information from forms that clients may fill out and send to Paladin in connection with its services (such as name, address, and social security number).
  • Information a client may give Paladin orally.
  • Information about the amount clients have invested in an investment fund.
  • Information about any bank account clients may use for transfers between a bank account and a capital account of an investment fund.

Paladin does not sell or disclose client personal information to anyone except as permitted or required by law (for example, Paladin may share information collected about its clients with Paladin’s independent auditors and legal counsel and with regulators as it deems appropriate).

Additionally, a copy of an investor’s tax Form K-1 is included in a private investment fund’s tax return filed with the Internal Revenue Service.

Finally, Paladin may disclose information about its clients to any affiliated entity of Paladin and at the client’s written request (for example, by sending duplicate account statements or other information to someone designated by the client), and Paladin may disclose the client’s name in its marketing materials. Within Paladin, access to information about clients is restricted to those employees who need to know the information to service client accounts. Paladin employees are trained to follow its procedures to protect client privacy and are instructed to access information about clients only when they have a business reason to obtain it. Paladin reserves the right to change its privacy policy in the future, but Paladin will not disclose client nonpublic personal information, unless required by law, without giving the client an opportunity to instruct Paladin not to do so.

Compliance Statement

Ladies and Gentleman:

Reference is hereby made to the Public Pension Fund Reform Code of Conduct adopted by Paladin Homeland Security Holdings, LLC (together with its subsidiaries and affiliates over which it exercises exclusive control, but excluding any sponsored, managed or advised investment fund or any portfolio company thereof, “Paladin”) on December 10, 2011 (as amended, amended and restated, or supplemented from time to time in accordance with the terms thereof, the “Code”).  Capitalized terms used herein (including in the Exhibits attached hereto) without definition will have the meanings set forth in the Code.

As of the date hereof, to the best of its knowledge after due inquiry, Paladin makes the disclosures set forth in Exhibits A, B and C attached hereto pursuant to the Code and certifies that such disclosures are accurate.

Very truly yours, PALADIN HOMELAND SECURITY HOLDINGS, LLC

By: Mark Maloney, Chief Compliance Officer

Exhibit A,B,C

 

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