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PRIVACY POLICY NOTICE

This Privacy Policy explains the manner in which Polen Capital Management, L.L.C., collects, utilizes and maintains nonpublic personal information about the individuals with which it conducts or may conduct business. Polen considers privacy an essential aspect of its client relationships. This Privacy Policy applies only to nonpublic information about individuals who conduct business with Polen for personal, family, or household purposes and not business purposes (collectively, “Clients”).

Collection of Investor Information

Polen collects personal information about Clients from the following sources:

1. Account documentation, questionnaires and other information provided by the Client, or a fiduciary or other person acting on behalf of the Client, in writing, in person, by telephone, electronically or by any other means. This information includes, among other information, name, address, social security number, employment information, and financial and investment qualifications and objectives; and

2. Transactions in the Client’s account, including account balances, investments, contributions and withdrawals.

Disclosure of Nonpublic Personal Information

Polen may share nonpublic personal information about Clients or potential Clients with its affiliates, as permitted by law, including to assist Polen in offering or providing services and products to Clients. Polen does not disclose nonpublic personal information about Clients or potential Clients to nonaffiliated third parties, except as permitted or required by law. For example, Polen may share nonpublic personal information with nonaffiliated third parties, without the Client’s consent, in the following situations:

1. To respond to a subpoena or court order, judicial process or regulatory or governmental inquiry;

2. To protect or defend against fraud, unauthorized transactions (such as money) laundering), law suits, claims or other liabilities;

3. To service providers of Polen in connection with the administration and operations of Clients’ accounts, which may include attorneys, accountants, auditors, administrators or other

professionals;

4. To process or complete transactions requested by a Client; and

5. Upon consent of a Client to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the Client.

Polen Capital Management LLC

Proxy Voting Disclosure

The Firm will accept discretionary authority over a client’s proxy if the Firm has discretionary authority over the client’s advisory account and the advisory contract does not expressly state that the Firm will not be voting proxies or the client does not retain voting authority. At this time, the Firm does accept proxy voting authority for client accounts.

The Firm utilizes a third party service provider (Institutional Shareholder Services or “ISS”) for proxy voting matters. The Chief Compliance Officer has been delegated the authority for monitoring corporate actions, ensuring that voting decisions in accordance with these policies, and ensuring that proxies are submitted in a timely manner. The Chief Compliance Officer will also be responsible for ensuring that clients’ requests for these proxy voting policies and procedures and/or their voting information is responded to effectively within a prompt time period.

In voting proxies, the Firm’s votes will usually follow the recommendations of ISS. The Firm will rely on ISS to maintain proxy statements and records of proxy votes cast. The Firm will obtain an undertaking from ISS to provide a copy of the documents promptly upon request.

The Chief Compliance Officer will maintain a list of those companies which issue publicly traded securities and with which the Firm (or its affiliates) have such a relationship that proxies presented with respect to those companies may, or may not be perceived to give rise to a conflict of interest between the Firm and its clients. Examples of such a relationship include:

 Companies affiliated with directors, or immediate family members of directors of the Firm or of affiliates of the Firm;

 Companies affiliated with officers, or immediate family members of officers of the Firm or of affiliates of the Firm; and

 Companies that maintain significant business relationships with the Firm or of affiliates of the Firm, or with which the Firm or an affiliate of the Firm is actively seeking a significant business relationship.

In addition, any proxy vote that would result in increased compensation to the Firm or an affiliate due to increased or additional fees or other charges to be paid by the client as a result would also be considered a vote where the Firm has a conflict of interest. The Chief Compliance Officer will determine, based on a review of the issues raised by the conflict of interest, the nature of the potential conflict and, most importantly, given the Firm’s commitment to vote proxies in the best interests of client accounts, how the proxy will be handled. The Chief Compliance Officer will perform one the following duties as a result:

1. Disclose the conflict to the client(s), providing sufficient information regarding the matter and the nature of the Firm’s conflict, and obtaining consent before voting;

2. Employ ISS to advise in the voting of the proxy;

3. Employ ISS to vote the proxy on behalf of the Firm and its clients; or

4. Decline to vote the proxy because the cost of addressing the potential conflict of interest is greater than the benefit to the clients of voting the proxy.

Protection of Investor Information

Polen maintains physical, electronic and procedural safeguards that comply with federal standards to protect customer information. Within Polen, access to the personal and account information of Clients is restricted to those employees who need to know that information in the course of their job responsibilities.

Further Information

Polen reserves the right to change this Privacy Policy at any time. The examples contained within this notice are illustrations and are not intended to be exclusive. This notice complies with Federal law regarding privacy. Clients may have additional rights under other applicable foreign or domestic laws.