Ariel’s most important asset is its relationship to clients. Ariel’s entire staff is dedicated to serving its clients. Ariel strives to maintain clients’ trust and confidence, and it is Ariel’s policy not to share clients’ personal information with anyone unless it is for one of the following reasons:

• at a client’s direction;
• to provide a client with service or information about Ariel’s services;
• to maintain Ariel’s high standards of performance and compliance; or
• as required by law.

Clients, upon opening an account and on an as needed basis, submit to Ariel a variety of personal data, including address, telephone number and certain tax and financial information. Ariel generates reports to service client accounts such as trade tickets and account statements, and Ariel receives reports regarding client accounts, such as confirmations from securities firms.

In order to provide quality service, when placing orders or executing transactions, Ariel discloses information to others on a limited basis. These entities include custodians and securities firms. Ariel also may provide information to companies that perform necessary services to properly maintain Ariel’s business, such as maintenance of computer systems and to accountants and attorneys who help Ariel assess and maintain performance and compliance standards. To protect and properly maintain this information, Ariel has established procedures and personnel practices that are designed to ensure confidentiality and protect Ariel’s clients’ records. A former client’s information is protected to the same extent as that of a current client.