Christian Brothers Investment Services, Inc. (“CBIS”) and CBIS Financial Services, Inc. (“CBISFS”) have adopted this Privacy Policy to set forth the principles we will follow in safeguarding information about our participant organizations (“Participants”).  CBIS is an investment adviser registered under the Investment Advisers Act of 1940; CBISFS is a broker-dealer registered under the Securities Exchange Act of 1934.  

1. We believe that privacy is important to all of our Participants and we are committed to maintaining the confidentiality and security of our Participants’ information.  Therefore, we shall protect information about our participants by maintaining physical, electronic and procedural safeguards that meet or exceed those required by law.  
   
2. All CBIS employees may have a need to know the information to provide services to our Participants and therefore will have access to this information.  
   
3. We shall not disclose information about our Participants to external organizations unless authorized by our Participants, required by law or necessary to provide our services to our Participants.
4. We shall not sell information about our Participants to anyone. 
   
5. We shall treat information about former Participants in the same manner we treat information about current Participants.
6. If CBIS or CBIS-FS begins to offer services to clients other than institutions, this policy shall be reviewed and revised to address compliance with Regulation S-P of the Securities and Exchange Commission regarding nonpublic personal information of consumers and customers.