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A. Scope of Application   

 Any associate or officer of the Advisor as well as any third party who is responsible for  the collection, use or sharing of partner information must adhere to this policy.   

B. Purpose  

This policy represents the Advisors commitment to protecting the privacy of each client  in a manner that is transparent and consistent with privacy related laws, regulations,  and regulatory guidance and is intended to mitigate compliance, legal, operational, and  reputational risks.  In accordance with the Gramm – Leach Bliley Act, the Advisor must  provide the privacy policy to all new clients and all existing clients on an annual basis  and will record this provision to document compliance.  

C. Policy Essentials  

Protect the privacy of each client in a manner that is transparent and consistent  with privacy related laws, regulations, and regulatory guidance and is intended  to mitigate compliance, legal, operational, and reputational risks.  • Ensure client information is used for the purposes for which it was collected.  • Prevent potential or further harm to clients, associates or officers (of the  Advisor) due to a privacy event, through the prompt identification and reporting  of privacy events.  

Please let me know if you have any questions about my commitment to maintaining the highest  possible standards of confidentiality.    

Jeffrey H. Wright

President and Founder 

Fish Creek Value Management, LLC / Fish Creek Capital

IARD# 291643 / IA#5752