EFM INVESTMENTS & ADVISORY, LLC 

REQUIRED DISCLOSURES TO INVESTORS 

General

Federal and state regulations require financial institutions to maintain clear, conspicuous and accurate  statements of their privacy policies including the information collected about their clients, with whom they share  the information and how they protect the information. FTC Financial Privacy Rule requires EFM Investments  & Advisory, LLC. (“EFM”) and each private investment fund (including the Fund) advised by EFM to distribute  this privacy policy to Fund investors who are natural persons.

Overview

EFM and the Fund (“we” or “us”) look to protect nonpublic personal data and provide this policy to clients and  investors regardless of whether they are natural persons. The policy set forth below is intended to be compliant  with the federal and state regulations as applied to EFM and the Fund.

Privacy Policy Details

• Collection of Information. From time to time non-public personal information may be collected as  required for legitimate business purposes. The following are sources of information collected:
  • Subscription Agreements, investor questionnaires and other forms, which may include an  investor’s name, address, Social Security number and personally identifiable financial information  such as personal income and bank account information;
  • Account history, including information about an investor’s capital account, such as capital  contributions, profit and loss allocations and distributions and withdrawals to and from the Fund;
  • Transactions with the Fund, including information EFM receives and maintains relating to  transactions with and through the Fund; and
  • Correspondence, written, telephonic or electronic, between investors and EFM, any of EFM’s  affiliates or any Fund service providers.

In addition to the sources listed above, EFM and the Fund may also collect this information from our Web sites.

• Disclosure of Information. EFM and the Fund may share all of the information that we collect, as  described above, with our affiliates in order to service investor accounts.

In addition, EFM and the Fund may disclose all of the information that we collect about investors to  certain third parties who are not affiliated with EFM or the Fund under one or more of the following  circumstances:

• As Authorized – if an investor requests or authorizes disclosure of the information.
• As Required by Law – for example, to cooperate with regulators or law enforcement authorities.
• As Permitted by Law – for example, sharing information with companies that maintain, process or  service Fund or investor accounts or financial products and services or that effect, administer or  enforce Fund or investor transactions is permitted. Among other activities, EFM may share  information with persons acting in a representative or fiduciary capacity on a Fund’s or an  investor’s behalf. EFM believes that sharing of information for these purposes is essential to  providing investors with necessary or useful services with respect to their accounts.

Information Safeguarding Policy

EFM and the Fund restrict access to non-public personal information about Fund investors internally to those  of our employees and our agents (e.g., auditors, attorneys and accountants) who need to know the information  to enable us to provide our services to Fund investors. EFM maintains physical, electronic and procedural  safeguards to guard an investor’s non-public personal information.