The Securities and Exchange Commission adopted Regulation S-P in 2001, which requires financial institutions to disclose their privacy policies regarding clients' personal non-public information on an annual basis. It also places limits on the disclosure of such information to third parties without consent. At Lewis Capital Management, LLC, the privacy of your personal information always has been and will continue to be of paramount importance. We protect the security and confidentiality of the personal information that we obtain while providing you investment advisory services. Details of our privacy policies and procedures are set forth under the heading "Lewis Privacy Policy" below. If you have any questions or concerns, please do not hesitate to call.

Lewis Privacy Policy

1. In the normal course of providing you with investment advisory services, we collect personal information about you from the following sources: Information we receive from you on applications or other forms; from copies of brokerage statements and other documents you may provide to us from time to time; and from the transactions in your accounts that we manage.

2. We do not disclose any personal information about our clients or former clients to third parties, unless one of the following limited exceptions applies: We may disclose personal information to other entities if required in connection with processing or servicing your transactions or account(s), such as to your stock broker, a transfer agent or custodian; we may disclose or report personal information where we believe in good faith that disclosure is required or permitted under law, for example, to cooperate with regulators or law enforcement authorities, to perform authentication checks, or for institutional risk control. Outside of these exceptions, we will not share your personal information with third parties unless you have specifically asked us to do so.

3. We restrict access to personal information about you to those employees, if any, who need to know that information in connection with providing investment advisory services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.