Privacy Policy. In managing your account, Chartwell Investment Partners (CIP) obtains certain nonpublic personal information about you. CIP keeps this information confidential and safeguards it from being improperly disclosed. CIP only uses and discloses this information to the extent necessary to provide services to you or as otherwise permitted by law. This policy applies to existing and former clients of CIP.

Information Collected and Disclosed. This Privacy Policy relates to nonpublic personal
information that is personal to you and possibly your family and generally includes:

• Your name, address and telephone numbers;
• Your employment information, including your salary and benefits;
• Information relating to your financial situation, including your income and assets, liabilities and debts; and
• Information about your account assets and transactions, brokerage and custody arrangements for your account.

CIP only discloses this nonpublic personal information about you to those persons that provide necessary services to your account or as permitted by law or authorized by you.

Safeguarding Your Information. CIP restricts access to nonpublic personal information about you only to those persons who need it to provide services to you or who are permitted by law to receive it. CIP maintains physical, electronic and procedural safeguards to protect the confidentiality of all nonpublic information CIP has about you.

If you have any questions regarding this Policy, please contact Greg Hagar at 610-407-4840.