In June of 2000, the Securities and Exchange Commission released "Regulation S-P," a rule intended to protect the privacy of nonpublic financial information about individuals. Regulation S-P requires us to inform our clients of our privacy policies by July 1, 2001.

Please find attached Stewart and Patten's Privacy Policy. In many respects this is simply a formal presentation of the way we have practiced business for many years. We value our relationship with you, and we know that respect for your privacy is the very foundation of that relationship. Since our company was founded in 1942, we have built a reputation based on trust. Advances in technology have made vigilance over safeguarding private information all the more important.

STEWART AND PATTEN CO., LLC PRIVACY POLICY
JUNE 1, 2001

Our Commitment to your Privacy -

At Stewart and Patten, the interests of our clients always come first. As part of our firm's long tradition of trusted client service, the confidentiality of client information has been, and will continue to be, paramount. We maintain high standards to safeguard your personal information at all times, and we will remain vigilant in protecting that information.

We collect personal financial information only to meet fiduciary, legal and regulatory requirements. We never rent or sell your name or other personal financial information. We only share information with those individuals or companies authorized by you in writing or verbally. These individuals and organizations are also required to protect the confidentiality and security of that information. Generally, this is limited to:

- Companies providing brokerage and custodial services for your account.
- Companies or individuals providing you legal or accounting service.
- Other individuals specifically empowered by you.

In addition, government agencies can be allowed access to your information under state and federal law.

Types of personal information that we collect -

We collect information from you such as your name, address, social security number, telephone number, and e-mail address. In addition, our systems collect and retain information about your financial transactions, such as securities bought and sold, credit card and checking transactions, fund transfers, initial costs of securities and realized and unrealized capital gains.

How we will protect your personal information -

We will protect the confidentiality and security of your information via:

People - We restrict access to your personal financial information to personnel who need that information to provide you with our investment management service. All principals and employees of our firm have been instructed not to release your personal financial information without your consent.

Policies & Procedures - We maintain and monitor physical, electronic and procedural safeguards, updating them as needed so that we may guard your personal information.

Security - We use leading security and encryption methods to help us prevent unauthorized access of your personal financial information.