Privacy Policy

Dated as of February 2006

At MAXAM Capital Management LLC (“MAXAM”) we recognize the importance of protecting the Shareholders’ privacy. As such, the Fund and the Investment Manager have policies in place to maintain the confidentiality and security of the Shareholders’ information.

Categories Of Information We May Collect

In the normal course of business, we may collect the following types of information:


How We Use Your Information That We Collect

Any and all nonpublic personal information received by the Investment Manager with respect to the Shareholders who are natural persons, including the information provided to the Fund by a Shareholder in the subscription documents, will not be shared with nonaffiliated third parties which are not service providers to the Fund or the Investment Manager without notice to or prior consent from such Shareholders. In the normal course of business, we may disclose the kinds of nonpublic personal information listed above to nonaffiliated third party service providers involved in servicing and administering products and services on our behalf. Such service providers include but are not limited to the Administrator, the auditors and the legal advisors of the Fund. Additionally, the Fund and/or the Investment Manager may disclose such nonpublic personal information as required by law (such as to respond to a subpoena or to prevent fraud) or disclosure that may be required by the Uniting and Strengthening America Act By Providing Appropriate Tools Required To Intercept and Obstruct Terrorism (USA PATRIOT) Act of 2001.

The same privacy policy will also apply to the former Shareholders.

Confidentiality and Security

We restrict access to nonpublic personal information about our customers to those employees and agents who need to know that information in order to provide products and services to you. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information. In addition, if we choose to dispose of any of your nonpublic personal information that we are not legally bound to maintain, then we will do so in a manner that reasonably protects such information from unauthorized access.

For questions about this privacy policy, please contact the Investment Manager.


Past performance is not indicative of future returns.