Terms of Use

READ THESE TERMS AND CONDITIONS ("TERMS") CAREFULLY BEFORE USING THE SERVICES DESCRIBED HEREIN.

By accessing www.AcadiaAssetManagement.com, (the "Site") the pages contained on it, and the products, services, information, tools and material contained or described herein, you acknowledge your agreement with and understanding of the following terms of use.

By using this Site you acknowledge and you have read these terms and that you agree to be bound by them. If you do not agree to all of the terms then you are not an authorized user and should not use this Site.

Acadia Asset Management, LLC ("Acadia") reserves the right to change, modify, add or remove portions of these terms and this Site for any reason and at any time. Such changes shall be effective immediately upon posting. You acknowledge that by accessing the Site after we have posted changes to these terms or to the Site itself you are agreeing to these terms as modified.

Disclaimer

Nothing contained on www.AcadiaAssetManagement.com, (the "Site") constitutes tax, legal, insurance or investment advice. Neither the information, nor any opinion, contained on this Site constitutes a solicitation or offer by Acadia or its affiliates to buy or sell any securities, futures, options or other financial instruments, nor shall any such security be offered or sold to any person in any jurisdiction in which such offer, solicitation, purchase, or sale would be unlawful under the securities laws of such jurisdiction. Decisions based on information contained on this Site are the sole responsibility of the visitor. In exchange for using this Site, the visitor agrees to indemnify and hold Acadia Asset Management, LLC ("Acadia"), its officers, directors, employees, affiliates, agents, licensors and suppliers harmless against any and all claims, losses, liability, costs and expenses (including but not limited to attorneys' fees) arising from your use of this Site, from your violation of these Terms or from any decisions that the visitor makes based on such information.

The information and services provided on this Site are provided "AS IS" and without warranties of any kind, either expressed or implied. To the fullest extent permissible pursuant to applicable law, Acadia disclaims all warranties, including, but not limited to, any warranty of non-infringement of third-party rights and any implied warranties of merchantability and fitness for a particular purpose. Acadia does not warrant, either expressly or impliedly, the accuracy or completeness of the information, text, graphics, links or other items contained on this Site and does not warrant that the functions contained in this Site will be uninterrupted or error-free, that defects will be corrected, or that the Site will be free of viruses or other harmful components. Acadia expressly disclaims all liability for errors and omissions in the materials on this Site and for the use or interpretation by others of information contained on the Site.

SEC Materials

BEFORE ACQUIRING THE SHARES OF ANY MUTUAL FUND BY PURCHASE OR EXCHANGE, IT IS YOUR RESPONSIBILITY TO READ THE FUND'S PROSPECTUS.

Certain information provided through this Site has been filed with the Securities and Exchange Commission ("SEC") (such information being referred to as "SEC information"). The SEC information and other public disclosures contained on this Site contain forward-looking statements within the meaning of the Private Securities Litigation Reform Act, with respect to Acadia's future financial or business performance, strategies or expectations. Forward-looking statements are typically identified by words or phrases such as "trend," "potential," "opportunity," "pipeline," "believe," "comfortable," "expect," "anticipate," "current," "intention," "estimate," "position," "assume," "outlook," "continue," "remain," "maintain," "sustain," "seek," "achieve," and similar expressions, or future or conditional verbs such as "will," "would," "should," "could," "may" or similar expressions.

Acadia cautions that forward-looking statements are subject to numerous assumptions, risks and uncertainties, which change over time. Forward-looking statements speak only as of the date they are made, and Acadia assumes no duty to and does not undertake to update forward-looking statements. Actual results could differ materially from those anticipated in forward-looking statements and future results could differ materially from historical performance.

In addition to factors previously disclosed in Acadia's SEC information and those identified elsewhere on this Site, the following factors, among others, could cause actual results to differ materially from forward-looking statements or historical performance: (1) the introduction, withdrawal, success and timing of business initiatives and strategies; (2) changes in political, economic or industry conditions, the interest rate environment or financial and capital markets, which could result in changes in demand for products or services or in the value of assets under management; (3) the relative and absolute investment performance of Acadia's investment products, including its separately managed accounts; (4) the impact of increased competition; (5) the impact of capital improvement projects; (6) the impact of future acquisitions or divestitures; (7) the unfavorable resolution of legal proceedings; (8) the extent and timing of any share repurchases; (9) the impact, extent and timing of technological changes and the adequacy of intellectual property protection; (10) the impact of legislative and regulatory actions and reforms and regulatory, supervisory or enforcement actions of government agencies relating to Acadia; (11) terrorist activities and international hostilities, which may adversely affect the general economy, domestic and local financial and capital markets, specific industries, and Acadia; (12) the ability to attract and retain highly talented professionals; (13) fluctuations in foreign currency exchange rates, which may adversely affect the value of advisory fees earned by Acadia; (14) the impact of changes to tax legislation and, generally, the tax position of the Company; (15) Acadia's success in maintaining the distribution of its products; (16) the ability to maintain our reputation and promote our brands; (17) the timely development and acceptance of our new products and services and the perceived overall value of these products and services by users;

Restrictions on Offer and Solicitation and Distribution

The information in the Site is descriptive of Acadia as a whole and the services, securities and financial instruments described may not be suitable for you or available in the jurisdiction in which you are located.

Acadia will not treat users of this Site as its clients by virtue of them accessing it. Users of this Site should seek the advice of their independent financial adviser prior to taking any investment decision on the basis of any information contained herein and no information herein constitutes general or specific investment, legal, tax or accounting advice of any kind. The information contained on this Site may relate to the products and services of a person or entity that is located in a jurisdiction other than that in which you are located. Accordingly the rules for the protection of private customers that apply in the jurisdiction in which you are located may not apply in relation to such products and services.

Fund Disclosures

Investments in an Acadia product or client account are not bank deposits and are not insured or guaranteed by the Federal Deposit Insurance Corporation, any other government agency, any bank or any other entity.

Please carefully consider a fund's investment objective, risks, charges and expenses before investing. For this and other information, call or write to Acadia. Read it carefully before you invest or send money.

Risk Considerations

Past performance should not be taken as an indication or guarantee of future performance, and no representation or warranty, express or implied, is made regarding future performance. Investing entails risks, including possible loss of principal. The price of, value of and income from securities or financial instruments can fall as well as rise. Certain investments are subject to high volatility, and may experience sudden and large falls in their value. Losses may equal or exceed your original investment. Some investments may not be readily realizable and it may be difficult to sell or realize those investments. Similarly it may prove difficult for you to obtain reliable information about the value, or risks, to which such an investment is exposed. There are also special risk considerations associated with small-company investing, single-industry funds or investment strategies, or other special, aggressive or concentrated investment strategies, such as the use of leverage or derivatives. Investors in securities effectively assume these risks.

Trademarks, Copyrights and other Intellectual Property

The content contained on this Site is owned or licensed by Acadia and is protected by applicable copyrights, trademarks, service marks, and/or other intellectual property rights. Such content is solely for your personal, non-commercial use. You may not copy, distribute, modify, post, frame or deep link this Site, including any text, graphics, video, audio, software code, user interface design or logos. You may download material displayed on this Site for your personal use provided you also retain all copyright and other proprietary notices contained on the materials. You may not distribute, modify, transmit, reuse, repost, or use the content of this Site for public or commercial purposes, including all text, images, audio, and video, without Acadia's written permission. Modification or use of the materials for any other purpose violates Acadia's intellectual property rights.

All trademarks, service marks, trade names, and logos displayed on this Site are proprietary to Acadia and/or their respective owners. Nothing contained on this Site should be construed as granting, by implication, or otherwise, any license or right to use any trademark displayed on this Site without the written permission of Acadia or such other third party that may own the trademark displayed on this Site. Your use of the trademarks displayed on this Site, except as provided herein, is strictly prohibited.

The use of the images displayed on this Site by you, or anyone else authorized by you, is prohibited. Any unauthorized use of the images may violate copyright laws, trademark laws, and the laws of privacy and publicity, and communications, as well as other regulations and statutes. If you download any information from this Site, you agree that you will not copy it or remove or obscure any copyright or other notices or legends contained in any such information.

Links to Other Sites

Acadia may establish links between this Site and one or more Sites operated by third parties. Acadia has no control over any such other Sites, the contents therein or the products/services offered. The existence of any such links shall not constitute an endorsement of, or representation or warranty by Acadia regarding such Sites, the contents of the Sites, the products or services of the Sites or the operators of the Sites. Your access to and use of such linked Sites is governed by the terms of use and privacy policies of those Sites, and shall be at your own risk. Acadia disclaims responsibility for the privacy policies and customer information practices of third-party internet Sites hyperlinked from our Site.

Links to Acadia from Other Sites

You shall not display hyperlinks on your Sites to any Site owned or operated by Acadia. If you desire to display on your Site a hyperlink to an Acadia Site, you must enter into a written agreement with Acadia governing such display. Access to any Acadia Site does not authorize you to use any of Acadia's names, logos, trademarks or copyrighted material, and you agree not to do so without Acadia's express written consent. Requests to display hyperlinks on your Sites to Acadia Sites should be e-mailed to info@AcadiaAssetManagement.com Transmissions to and From this Site

Electronic communications can be intercepted by third parties and, accordingly, transmissions to and from this Site may not be secure. Communications to Acadia, particularly those containing confidential information, may be sent by mail to: Acadia Asset Management, LLC, One Penn Plaza, 36th Floor, New York, NY 10119. Acadia shall be free to use, for any purpose, any ideas, concepts, know-how, or techniques provided by a Site user to Acadia through this Site.

Privacy Policy

Please review our Privacy Policy, which is a part of this Agreement and hereby incorporated by reference, to learn about our information collection practices and the measures we take to preserve the privacy and security of your information.

E-mail and Marketing

Individuals who complete the registration process to access restricted segments of Acadia's Site are at the same time granting Acadia permission to send them e-mail messages for marketing and general communication purposes at the e-mail address they have provided. This service may be discontinued at any time by responding to the email with "Unsubscribe" in the subject line.

Jurisdiction and Governing Law

The information provided on this Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject Acadia or its affiliates to any registration requirement within such jurisdiction or country. Each investment product and service referred to on this Site is intended to be made available to only U.S. residents. This Site will not be considered a solicitation for or offering of any investment product or service to any person in any jurisdiction where such solicitation or offering would be illegal.

The laws of the State of New York govern these Terms without regard to conflict of law provisions. If you take legal action relating to these Terms, you agree to file such action only in the New York State Supreme Court located in New York, NY, or the United States District Court for the Southern District of New York, and you consent and submit to the personal jurisdiction of those courts for the purpose of litigating any action with Acadia, its affiliates or with any funds referenced in this Site.

Limitation of Liability

ACADIA AND ITS AFFILIATES AND THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES OR AGENTS WILL NOT BE LIABLE TO YOU OR ANYONE ELSE FOR ANY DAMAGES OF ANY KIND, INCLUDING, BUT NOT LIMITED TO, DIRECT, CONSEQUENTIAL, INCIDENTAL, SPECIAL OR INDIRECT DAMAGES (INCLUDING BUT NOT LIMITED TO LOST PROFITS, TRADING LOSSES OR DAMAGES THAT RESULT FROM USE OR LOSS OF USE OF THIS SITE), EVEN IF ACADIA HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES, INCLUDING, WITHOUT LIMITATION, FROM THE USE OR ATTEMPTED USE OF THIS SITE OR ANOTHER LINKED SITE. IF YOU LIVE IN A STATE THAT DOES NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY OR INCIDENTAL OR CONSEQUENTIAL DAMAGES, OR IF YOU ACCESS THE SITE SOLELY THROUGH AN ARRANGEMENT WITH YOUR EMPLOYER OR PLAN SPONSOR, SOME OR ALL OF THESE LIMITATIONS AND EXCLUSIONS MAY NOT APPLY TO YOU.

Timeliness of Content

All content on this Site is presented only as of the date published or indicated, and may be superseded by subsequent market events or for other reasons. In addition, you are responsible for setting the cache settings on your browser to ensure you are receiving the most recent data.

Prohibited Uses

Except as otherwise stated in these Terms or as expressly authorized by Acadia in writing, you may not:

• Use this Site in any manner that could damage or overburden any Acadia server, or any network connected to any Acadia server, as all servers have limited capacity and are used by many people;
• Use this Site in any manner that would interfere with another party's use of the Site;
• Include the term "Acadia," or any Acadia trademark or executive's name, or any variation of the foregoing, as a meta-tag, hidden textual element;
• Use any robot, spider, intelligent agent, other automatic device, or manual process to search, monitor or copy this Site or the reports, data, information, content, software, products services, or other materials on, generated by or obtained from this Site, whether through links or otherwise (collectively, "Materials"), without Acadia's permission, provided that generally available third-party web browsers may be used without such permission; or
• Use this Site or the Materials in any manner that could create impression of affiliation, sponsorship or endorsement by Acadia.

Password Security and Notification

Certain parts of the Site are protected by passwords or require a login and are restricted to authorized users only. You may not obtain unauthorized access to such parts of the Site, or to any other protected materials or information, through any means not intentionally made available by Acadia for your specific use. If you have a Personal Identification Number (PIN) for access to non-public areas of the Site, you are solely responsible for all activities that occur in connection with your PIN. Accordingly, you should take all reasonable steps to protect the confidentiality of your PIN. Notify Acadia immediately if you become aware of any disclosure, loss, theft or unauthorized use of your PIN.

Unauthorized Use of Content

You agree to defend, indemnify and hold harmless Acadia, its affiliates and each of their respective officers, directors, members, partners, managers and employees against any losses, damages, claims, liabilities and costs (including reasonable attorneys fees) to the extent resulting from or arising out of any unauthorized or otherwise inappropriate use of any of the content of this Site attributable to you or which occurs through the use of your ID.

Termination

Acadia may terminate your access to the Site for any reason, without prior notice.

Waiver

No waiver by Acadia of any right under or term or provision of these Terms will be deemed a waiver of any other right, term, or provision of these Terms at the time of such waiver or a waiver of that or any other right, term, or provision of these Terms at any other time.

Integration and Severability

If any provision of these Terms is deemed unlawful, void, or for any reason unenforceable, then that provision will be deemed severable from these Terms and will not affect the validity and enforceability of the remaining provisions.

The preceding Terms of use represent the entire agreement between Acadia and the visitor relating to the subject matter herein.

Privacy Policy

Acadia Asset Management, LLC and all its affiliates (hereinafter referred to as "Acadia", "we" or "us") are committed to maintaining the privacy of every current, former and prospective customer. We recognize that you entrust important personal information to us, and we wish to assure you that we take seriously our responsibilities in protecting and safeguarding this information. This Privacy Policy ("Policy") describes in detail how we deal with information that we collect on this website (the "Site").

This Policy may be updated at any time. Please ensure that you regularly read the latest version of this page. The first paragraph of the Policy tells you when the last update was made.

Information We Collect

We may collect information about you when you use this Site or when you apply for or use other services offered by Acadia in the following ways:

We may send cookies to your computer. Cookies are strings of information that are sent out by a website and saved in your computer. We may use session specific cookies to automatically collect data about website usage when you visit this Site, including your IP address, "click-stream" data regarding the portions of the site that you visit and the information or other services you obtain or input (including domain name, Internet service provider, protocol, browser type, operating system etc.) ("Usage Information"). This information is collected primarily for purposes of administering the Site, compiling demographic information and monitoring usage and performance of the Site. If you turn off the cookie function you may not receive all the information on the website.

If you register to use the password-protected portions of our site, we will ask you to provide us with certain information about yourself. This information may include your name, company name, title, address, country of residence, e-mail address, telephone number, account number, assets, income and financial situation. We use such information about you to verify your identity and eligibility to receive certain products or services, to provide information to you about products and services that we believe may be of interest to you, to record your interest in products and services that we offer, and to respond to your requests for information.

We may also use cookies on such portions of our Site to collect Usage Information, and to facilitate your movement within the Site. We may collect information concerning the attachments you open within newsletters that are sent to you electronically.

We may also collect personal information about you from applications, forms or questionnaires you may complete or agreements you enter into with us or in the course of your establishing or maintaining a customer relationship with us, including information about your credit history or financial situation, and your transactions with us or others who provide services to us.

If you decline to provide us with the personal information we require then we may not be able to make investment products available to you or to provide other services to you. Security of Data Transfer

Please note that data that is transported over an open network, such as the Internet or e-mail, may be accessible to anybody. Acadia cannot guarantee the confidentiality of any communication or material transmitted via such open networks. When disclosing any personal information via an open network, you should remain mindful of the fact that it is potentially accessible to others, and consequently, can be collected and used by others without your consent. A third party may therefore be able to trace an existing bank account or relationship or one that is subsequently created. Even if both the sender and recipient are located in the same country data may also be transmitted via such networks to other countries regularly and without controls, including to countries that do not afford the same level of data protection as your country of domicile.

Your data may be lost during transmission or may be accessed by unauthorized parties. We do not accept any liability for direct or indirect losses as regards the security of your data during its transfer via Internet. Please use other means of communication if you think this is necessary or prudent for security reasons.

Protection and Use of Personal Data

We use your personal information to enhance the quality of the products or services we wish to provide to our customers or in connection with your investments with or through us and to maintain contact details for those with whom we deal. We maintain physical, electronic and procedural safeguards to guard your personal information, including firewalls and individual passwords. We do not use for purposes other than as set out above, or disclose to any third party any personal information about our customers or former customers, except with such customer's consent or as otherwise permitted or required by law. In cases where we believe that additional products and services may be of interest to you, we may share your personal information with affiliates of Acadia to the extent permitted by applicable law. We may also disclose this information to firms that perform services on our behalf to the extent permitted by applicable law. These service providers are required to treat the information confidentially and use it only for the purpose for which it is provided. Certain jurisdictions may have more stringent privacy requirements that will prevent disclosure of your personal information to any other person or entity, including affiliates.

We will retain your personal information in accordance with applicable data protection laws for so long as it is needed.

Links

This Site may contain hyperlinks to other websites that are not operated or monitored by Acadia. These other websites are not subject to this Policy and we are not responsible for their content or for the policy they apply to the treatment of personal data. We recommend that you read the policy used by these websites and check how these websites protect your personal data and whether they are trustworthy.