ELLINGTON MANAGEMENT GROUP, L.L.C.
AND ALL AFFILIATES
(collectively, “ELLINGTON”)

PRIVACY POLICIES AND PROCEDURES

Confidential Client Information

            In the course of Ellington’s investment advisory activities, Ellington gains access to non-public information about clients of Ellington, or about customers of Ellington’s clients.  Such information may include personal financial and account information, information relating to services performed for or transactions entered into on behalf of clients, advice provided by Ellington to clients, and data or analyses derived from such non-public personal information (collectively referred to as “Confidential Client Information”).  All Confidential Client Information, whether relating to Ellington’s current or former clients, is subject to these Privacy Policies and Procedures.  Any doubts about the confidentiality of information must be resolved in favor of confidentiality.

Non-Disclosure of Confidential Client Information

●          Ellington does not share Confidential Client Information with any third parties, except in the following circumstances:

●          As necessary to provide the service that the client requested or authorized, or to maintain and service the client’s account.  Ellington will require that any financial intermediary, agent or sub-contractor utilized by Ellington (such as brokers, fund administrators, attorneys or auditors) comply with substantially similar standards for non-disclosure and protection of Confidential Client Information and use the information provided by Ellington only for the performance of the specific service requested by Ellington.

●          As required by regulatory authorities or law enforcement officials who have jurisdiction over Ellington, or as otherwise required by any applicable law. 

●          To the extent reasonably necessary to prevent fraud, unauthorized transactions or liability.

●          To companies that perform marketing and other services on our behalf, such as placement agents and solicitors, or to other financial institutions with whom we have joint marketing agreements, but only the following Confidential Client Information:  information we receive from you in correspondence, subscription documents, or other forms.

●          Ellington employees are prohibited, either during or after termination of their employment with Ellington, from disclosing Confidential Client Information to any person or entity outside Ellington, including family members, except under the circumstances described above. 

●          An Ellington employee is permitted to disclose Confidential Client Information only to such other Ellington employees who need to have access to such information to deliver Ellington’s services to the client.

●          Ellington employees are prohibited from making unauthorized copies of any documents or files containing Confidential Client Information and, upon termination of their employment with Ellington, must return all such documents to Ellington.

●          Any Ellington employee who violates the non-disclosure policy described above may be subject to disciplinary action, including possible discharge, whether or not he or she benefited from the disclosed information.

Security of Confidential Personal Information

●          Ellington restricts access to Confidential Client Information to those employees who need to know such information to provide Ellington services to clients.

●          Files containing Confidential Client Information shall be maintained in a secure compartment or receptacle.

●          All electronic or computer files containing any Confidential Client Information shall be password secured and firewall protected from access by unauthorized persons.

●          Any conversations involving Confidential Client Information, if appropriate at all, must be conducted by Ellington employees in private, and care must be taken to avoid any unauthorized persons overhearing or intercepting such conversations.

Privacy Notices

●          Ellington shall provide each client with initial notice of Ellington’s current Privacy Policies and Procedures at the time the client relationship is established.

●          Ellington shall provide each client with a new notice of Ellington’s current Privacy Policies and Procedures at least annually.

Enforcement and Review of Privacy Policies and Procedures

The Chief Operating Officer is responsible for reviewing, maintaining and enforcing these policies and procedures.  The Chief Operating Officer may take any disciplinary or other action as he/she may deem appropriate.  The Chief Operating Officer is also responsible for conducting appropriate employee training to ensure employee adherence to these policies and procedures.