Our most important asset is our relationship with our clients. We understand that our clients have entrusted us with private financial information, and we do everything that we can to maintain that trust.

The following describes the approach by Research Affiliates to privacy and how personal information about our clients is collected and used.

II. Overview of Privacy Policy
A. Definition.
The Research Affiliates privacy policy applies to consumers who are current or former clients or who use the services of Research Affiliates.

The law allows clients to "opt out" of only certain kinds of information sharing with third parties. Research Affiliates does not share personal information about its clients with any third parties, which trigger the "opt out" rights. Clients of Research Affiliates are automatically "opted out".

B. Sharing of Personal Information.
Research Affiliates shares our client's personal information only in the following limited circumstances:

1. We disclose personal information to companies that assist us in processing transactions for your account, such as executing trades at an exchange.

2. We may on occasion enter into contracts with third parties to assist us in servicing your account. For example, we may enter into a contract for the printing and mailing of account statements. Any such contract would prohibit the service provider from using our client's personal information for the service provider's own purposes and the third party is required to maintain the confidentiality of our client's personal information.

3. We may also enter into a "joint marketing relationship" with a financial institution, if we believe that our clients may be interested in hearing about its products and services. If we enter into such a relationship, the contract will specify that the financial institution will protect the confidentiality of the limited client information we share (e.g. name and address) and that our client's personal information will be used solely for the joint marketing arrangement.

4. We may disclose or report personal information to the extent we reasonably believe in good faith that the law requires disclosure or reporting. For example, disclosure of personal information of our clients may be required to cooperate with regulators or law enforcement authorities for institutional risk controls or authentication checks.

C. Collection of Personal Information.
We collect personal information in the normal course of business in order to better administer your accounts and to serve you better.

1. We collect information from our clients when an account is first opened. This information may include name, address, Social Security Number and information about a client's financial interests. We may also collect information from consumer-reporting agencies to verify our client's identity.

2. We may collect information through use of "cookies" when we open our website to clients.

3. We collect and maintain personal information about client transactions, including balances, positions and history in order to administer and maintain client accounts.

D. Protection of Personal Information.
We use client personal information to better serve our client's needs.

1. We use good faith efforts to protect the confidentiality and security of our client's personal information. Companies that we hire to provide support services are not allowed to use our client's personal information for their own purposes and are contractually required to maintain strict confidentiality and not to use our client's personal information in any way other than as expressly authorized by us.

2. We restrict access to personal information of our clients only to our employees and agents for legitimate business purposes only. All employees are contractually obligated to maintain the confidentiality of our client's personal information and are required to safeguard such information.

3. We maintain physical, electronic and procedural safeguards to protect our client's personal information.

E. Maintenance of Personal Information.
1. We periodically evaluate our efforts to maintain the confidentiality of out client's personal information and we make every effort to keep our client's personal information accurate and up-to-date. If a client identifies any inaccuracy in their personal information, or if a client needs to make a change to their personal information, please contact us so that we may promptly update our record.

2. In the future, if we decide to disclose client personal information inconsistent with the terms of this policy, we will notify our clients of the proposed change so that our clients have the option of opting out of the disclosure.

F. Privacy Online
Privacy, security and service in our online operations are just as critical as in the rest of our business. We therefore employ all of the safeguards described above, along with the following Internet-specific practices.

Research Affiliates uses a variety of proven protections to maintain the security of your online session. For example, we make extensive use of firewall barriers, encryption techniques and authentication procedures. We may also place cookies and similar files on your hard drive for security purposes, to facilitate site navigation, and to personalize your experience on our site.

When you visit our Internet sites, we may also collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our Web sites. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our Web design and functionality.

Your Connection
You may interact with us in various ways, and when you do, we may exchange information with parties in addition to those described above. For example, if you conduct business with Research Affiliates through your employer or investment professional, we may exchange the information we collect with them or with others at their direction. If we provide services to you on behalf of your employer, we may collect and exchange information such as payroll, banking and insurance data, in addition to the information listed above. Information collected from investment professionals' customers is not shared with Research Affiliates affiliates for marketing purposes, except with the consent of the investment professional or the customer.

If you interact with us directly as an individual investor, we may exchange information about you, as described above, with our affiliates to offer our products and services.

If you have any questions or concerns regarding this policy, please feel free to contact us at +1 (626) 584-2100 or by e-mail at info@rallc.com.