1. We will safeguard, according to strict standards of security and confidentiality, nonpublic, personal
information our customers share with us. “Nonpublic, personal information,” for example, would include such information as your name, address, social security number, and date of birth. We will maintain safeguards, physical and electronic, and conduct our business in a manner that keeps personal customer information secure.

2. We will limit the collection and use of customer information to the minimum we require to deliver
superior service and to administer our business, recognizing, however, that we do need to obtain
information to make suitable recommendations and to conduct appropriate “due diligence” in our
investment banking business. We collect personal information from customers from the following
sources:

• From customers on questionnaires, subscription agreements and related forms;
• From your transactions with us, our affiliates and others;
• From background checks (not consumer reports);
• From non-affiliated third parties.

Note - we will consult government-provided lists of known or suspected terrorists for individual
clients and those who can transact business on behalf of institutional clients.

3. Only authorized employees of St. Charles, their agents, and their staff who need to know your personal information will access and use it. Employees of St. Charles who violate our privacy policies are subject to discipline.

4. We will not share personal customer information (of either current or former customers) outside of St. Charles for any purpose other than the providing of investment banking services or the brokering or
underwriting of securities transactions on behalf of the customer, unless the disclosure has been
authorized by the customer or is permitted by law.

5. Whenever we retain other organizations to provide support services on behalf of St. Charles we will
require them to protect customers’ personal information.

6. When necessary, we will review and revise our privacy policies to protect personal customer information.

USA PATRIOT ACT NOTICE

Important Information about Procedures for Verifying Identities

To help the government fight the funding of terrorism and money-laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who transacts business with St. Charles.

What this means for you

Depending on the nature of the transaction, we may ask for your name, address, date of birth, social security number, and other pertinent information that will allow us to identify you. Additionally, we may ask to see your driver’s license or other government issued identifying documents.

Securities Investor Protection Corporation (SIPC)

St. Charles Capital is a SIPC member therefore pursuant to FINRA Rule 2266, you may obtain information about SIPC, including the SIPC brochure, by contacting SIPC at 202-371-8300 or www.sipc.org.

business continuity plan

privacy notice