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PRIVACY POLICY

MERIDIAN TRUST & INVESTMENT COMPANY

Overview
This Privacy Policy sets forth the policies of Meridian Trust & Investment Company with respect to the use, safeguarding and disclosure of nonpublic personal information collected by Meridian, in order to assure compliance with federal and applicable state laws and regulations concerning privacy of consumer financial information. We respect the financial privacy of our clients. We will comply with laws and regulations designed to secure that privacy, including all federal and applicable state privacy laws and regulations, as well as the Federal Fair Credit Reporting Act to the extent it may apply to our business practices. Each client’s relationship with us is important, and we want the client to understand our policies and practices about handling nonpublic personal information. We recognize the client’s right to privacy and that each client has the right to expect his or her nonpublic, personal information to remain private and secure. We will maintain standards to ensure that each client’s nonpublic personal information is private and secure at all times. We want each client to be aware of this Privacy Policy, which outlines how Meridian safeguards nonpublic personal information.

Scope of Policy
This Policy applies to our relationships with clients who inquire about or obtain services from us for personal, family and household purposes.

While this Policy does not apply to trusts for which we serve as trustee, employee benefit plans for which we provide fiduciary or other services, or business accounts, our trust, employee benefit plan and business clients’ information is also very important to us. We also respect the privacy of our business clients, and will also take steps necessary to protect their information. We will separately follow all of our policies and procedures to assure that we meet all fiduciary obligations with respect to the privacy of our clients’ information entrusted to us.

Strict Security Measures
We will establish security standards and procedures to prevent unauthorized access to client information. We will maintain physical, electronic and procedural safeguards to guard client information.

Limited Employee Access
We will establish procedures to limit employee access to information to only those employees with a business reason for accessing such information. We will educate our employees about the importance of confidentiality and client privacy.

Collection of Information
We collect information about clients to:

  • Accurately identify them;
  • Protect and administer their records, accounts and funds;
  • Understand their financial needs;
  • Save them time when they apply for new services; and
  • Comply with certain laws and regulations.

Sources of Information
The types and categories of information that we will collect and maintain include:

  • Information we receive from clients to open an account or provide investment advice or other services (such as the client’s home address, social security number, telephone number, financial information and investment objectives).
  • Information that we generate to service the client’s account or from our transactions with the client (such as account statements and other financial information).
  • Information on the client’s transactions with nonaffiliated third parties.
  • We will establish procedures so that the financial information we collect is accurate, current and complete. We will be committed to promptly correct any inaccurate information.

The Selective Sharing of Information
We may share information with any affiliated party, as well as with unaffiliated third parties external to us only in the limited circumstances that this Policy describes.

In order for us to provide investment management and other services to our clients, we will disclose our clients’ personal information in very limited instances, which will include:

  • Disclosures to nonaffiliated companies as permitted by law, including those who help us service client accounts (such as providing account information to brokers and custodians).
  • Other limited disclosures as permitted by law, for example, required reports to government entities.

We will not share clients’ nonpublic personal information with third parties for marketing purposes. We will not sell client information.

Former Clients
If a client ends his or her relationship with Meridian Trust & Investment Company, we will adhere to the information policies and practices described in this Policy.

109 S. Northshore Drive, Suite 400 I Knoxville, TN, USA 37919 I Telephone: (865) 342-4400 I Fax: (865) 546-0026 I Privacy Policy