Wellesley Asset Management, Inc.

Policies Regarding Client Non-Public Personal Information

We collect non-public personal information about you from information you give us on applications or other forms, and from information about your transactions and accounts with us, our affiliates or others.

We do not disclose any of your non-public personal information to anyone, except as required or permitted by law, or as authorized by you (for example, to your lawyer, accountant or other advisors).

We restrict access to your non-public personal information to those employees who need to know the information in order to provide our products and services to you. We maintain physical, electronic and procedural safeguards to guard your non-public personal information.