Our commitment to you:

As a 797 Capital LLC ("797 Capital") client, you have entrusted to our care not only your money but your personal and financial data as well. We recognize that your relationship with us is based on trust, and that you expect us to act responsibly and in your best interests. Because your personal and financial data are your private information, we hold ourselves to the highest standards in their safekeeping and use.

This means, most importantly, that we do not sell or reveal confidential client or former client information – whether it is your personal information or the fact that you are a 797 Capital client – to anyone, unless required by law. Instead, we use your information primarily for compliance purposes, to complete transactions or to make you aware of services that we offer.

The information we collect about you:

You provide personal information when you complete a 797 Capital client package. In addition to personal information you provide us, we may receive information about you that you authorize third parties to provide to us. We also may obtain personal information from third parties in order to verify your identity, to prevent fraud, or to help us identify services that may benefit you.

Personal information collected from any source may include, among other things, your name and address, Social Security or taxpayer identification number, date of birth, assets, income, account balances, investment activity, and accounts at financial institutions.

How we handle your personal information:

We do not sell personal information about current or former clients or their investments to third parties. Nor do we share such information, except with service providers, which have confidentiality obligations to us.

• In order to complete certain transactions or changes that you direct, it may be necessary to provide identifying information to our service providers or companies, individuals or groups that are not affiliated with 797 Capital. For example, if you ask to transfer assets from another financial institution to 797 Capital, we will need to provide certain information about you to that company to complete the transaction.
• In order to alert you to other services that 797 Capital offers, we may share your information within the 797 Capital family of affiliated companies. This would include, for example, sharing your information within 797 Capital to make you aware of new 797 Capital offerings.
• In certain instances, we may contract with nonaffiliated companies to perform services for us, such as prime brokerage and custodial services. Where necessary, we will disclose information we have about you to these third parties. In all such cases, we provide the third party with only the information necessary to carry out its assigned responsibilities, and only for that purpose. And we require these third parties to treat your private information with the same high degree of confidentiality that we do.
• Finally, we will release information about you if you direct us to do so, if we are compelled by law to do so, or in other legally limited circumstances (for example, to prevent fraud).

How we protect privacy online:

Our concern for the privacy of our clients naturally extends to those who use our website, 797capital.com.

• We do not use cookies to pull data from your hard drive, to learn your e-mail address, or to view data in cookies or other similar data files created by other websites. We will not share the information in these data files or give others access to it – except to help us better serve you.
• When you visit our website, we may collect certain technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on our website. This information may be used, for example, to alert you to software compatibility issues or to resolve technical or service problems, or it may be analyzed to improve our web design and functionality and our ability to serve you.

How we safeguard your personal information:

Within 797 Capital, we restrict access to personal information about you to those 797 Capital employees who need to know the information in order to perform their jobs. To protect your personal information, we maintain physical, electronic and procedural safeguards in keeping with customary standards and practices, and we review and adjust these safeguards regularly in response to advances in technology.

We will keep you informed:

We will disclose our privacy policy on our website. We reserve the right to modify this policy at any time, but rest assured that if we do change it, we will tell you promptly.

Please contact us via e-mail with any additional concerns / questions at: privacy (at) 797capital (dot) com

All persons using the 797 Capital LLC website (“Site”) expressly agree to the foregoing disclaimer, as a pre-condition to using this Site for any purpose, whatsoever. The materials on the Site including, without limitation, news articles, informational materials and all other manager-specific information, have been prepared for informational purposes only and do not constitute financial, legal, tax, or any other advice. All information contained, herein, is provided “as is”, and 797 Capital LLC expressly disclaims making any specific or implied warranties with respect to the fitness of the information contained, herein, for any particular usage, its merchantability, or its application or purpose. In no event shall 797 Capital LLC be responsible or liable for the correctness of any such material or for any damage or lost opportunities resulting from use of this data.

The information set forth on this website does not constitute an offer, solicitation or recommendation to sell or an offer to buy any securities, investment products or investment advisory services. Such an offer may only be made to qualified investors by means of delivery of a confidential private placement memorandum or other similar materials that contain a description of material terms relating to such investment. The information published is provided for informational purposes only. All information is subject to change or correction without notice. We make no representation that the information expressed herein is accurate, complete or current. Nothing contained in this website constitutes financial, legal, tax, or other advice.

Users of the 797 Capital LLC website may view, download, and print information and materials on this Site for personal and internal business use, provided that all hard copies contain all copyright and other applicable notices. Users may not reproduce, modify, copy, alter in any way, distribute, sell, resell, transmit, transfer, license, assign, or publish any information obtained from this Site. Users shall not use this site at any time for any purpose that is unlawful or prohibited and shall comply with any applicable local, state, national, or international laws or regulations when using this Site.

797 Capital LLC and the logos and marks included on the 797 Capital LLC site that identifies 797 Capital LLC services and products are proprietary materials. The use of such terms and logos and marks without the express written consent of 797 Capital LLC is strictly prohibited. Copyright in the pages and in the screens of the Site, and in the information and material, therein, is proprietary material owned by 797 Capital LLC unless otherwise indicated. All other trademarks, logos, and copyrights are the property of their respective owners. The unauthorized use of any material on the 797 Capital LLC website may violate numerous statutes, regulations, and laws, including, but not limited to, copyright, trademark, trade secret, or patent laws.

Please contact us via e-mail with any additional questions at: legal (at) 797capital (dot) com

Purpose and General Responsibilities
It is the general policy of 797 Capital LLC and its affiliates (the “Company”) to conduct its business activities and transactions with the highest level of integrity and ethical standards and in accordance with all applicable laws, rules and regulations. Obeying the law both in letter and in spirit is the foundation on which the Company’s ethical standards are built. The Company’s Business Partner Code of Conduct (“Code”) sets the Company’s expectations and standards for doing business and applies to agents, distributors, dealers, contractors, intermediaries, joint venture partners, suppliers, and other business partners (“Business Partners”). The following policy applies to you, our Business Partner.

The highest legal, moral, and ethical standards of honesty, integrity, and fairness are to be practiced in the conduct of the Company’s affairs. In order to meet this standard, each Business Partner is expected (i) to read and understand this Code and its application to the performance of their business responsibilities and (ii) to conduct themselves in accordance with this Code and to seek to avoid even the appearance of wrongdoing or improper behavior. Those who violate the standards in this Code will be subject to a cessation of business dealings and/or the reporting of violative conduct to appropriate regulatory and criminal authorities.

This code may be amended from time to time, and all updates are effective immediately upon posting. Business Partners are responsible for keeping up with changes in this Code. Other policies that govern the conduct of Business Partners may be established by the Company from time to time that supplement and are in addition to this Code.

Core Values

• Environmental Responsibility
• Integrity
• Respect
• Partnership
• Excellence in Performance
• Ethical Business Practices

Ethical Business Practices
Business Partners are expected to adhere to the following requirements:

Legal and Regulatory Compliance
Comply with the letter and spirit of all applicable national, state or regional, and local laws and regulations in the countries in which you operate.

Freedom of Association
Respect employees’ rights to join or not join any lawful organization, and shall comply with all applicable laws pertaining to freedom of association and collective bargaining.

Limitations on Gifts and Gratuities
Neither accept nor give payments or gifts to the Company’s employees, directors, officers, or third parties with an explicit or implicit suggestion of “quid pro quo”.

Antitrust and Competition Laws
Comply with all applicable antitrust and competition laws which prohibit agreements or actions that unreasonably restrain trade, are deceptive or misleading, or unreasonably reduce competition without providing beneficial effects to consumers.

Anticorruption and Bribery
Under the U.S. Foreign Corrupt Practices Act and other applicable anti-corruption laws in the countries where we do business, must not give or offer “anything of value” to a foreign government official or employee of a state-owned enterprise, including gifts and hospitality.

“Anything of value” can include bribes, kickbacks, gifts, entertainment and even contributions to a foreign government official’s favorite charity.

No Retaliation / Reporting
Employ a no-retaliation policy that permits workers to speak with the Company’s staff without fear of retaliation by management.

Conflicts of Interest
Disclose all actual or potential conflicts of interest and make decisions impartially and based on sound business reasoning.

Work Conditions and Human Rights

Wages and Benefits
Comply with all applicable wage and hour laws and regulations and provide legally mandated benefits.

Health and Safety
Provide a safe work environment and conduct yourself in a manner consistent with all applicable safety standards, including governmental requirements, operations- and facility-specific safety requirements, and contractual requirements.

Identify and respond to any public health impacts of your operations and use of your products and services.

Non-discrimination
Must not discriminate on the basis of race, gender, religion, ethnicity, nationality, sexual orientation, and/or political beliefs.

Human Rights
Must not violate basic human rights of life, liberty, and security. There shall be no harsh or inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers.

Records
Maintain and adhere to internal accounting controls and record-keeping policies.

Privacy and Confidentiality

Privacy
Abide by all regulations pertaining to the privacy of individuals and never disclose personal information to anyone outside the Company except as permitted by law and in the proper conduct of our business.

Confidentiality
Protect the Company’s confidential or proprietary information from any unauthorized access or disclosure.
Comply with all applicable laws and regulations governing the protection, use, and disclose of the Company’s proprietary, confidential, and personal information.

Inside Information
May not buy or sell securities that may be affected by inside information*, alone or with others.

May not pass along any inside information expressly or by way of making a recommendation for the purchase or sale of such securities based upon inside information.

*”Inside information” is material, nonpublic information about the securities, activities, or financial condition of a corporation, public entity, or other issuer securities. Material nonpublic information concerning market developments may also be constructed to be inside information.

Information is “material” if it could have an impact on the market prices of securities involved or if it is likely that a reasonable investor would consider the information important in deciding whether to purchase or sell the securities. Information may be material to one issuer but not to another, or to certain securities of an issuer but not to all securities of that issuer, (e.g., to equity, but not to debt).

Information should be considered “nonpublic” unless it is clearly public. Information is deemed public once it has been publicly announced or otherwise disseminated in a manner that makes the information available to investors generally without a breach of any confidentiality or fiduciary duty.

Social Media
May not use any form of social media to discuss, endorse, review, engage in, or otherwise comment on or promote the Company’s businesses, products, services, or programs without approval from the Company.

Responsibility

Assets of the Company
Protect the assets of the Company, as well as the assets of its customers, employees, and other Business Partners in accordance with the highest ethical standards, from theft, waste, or other types of loss.

Environmental Stewardship
Abide by the letter and spirit of all federal, state, and local environmental laws, as well as all applicable the Company policies and procedures.

Global Trade Compliance
Never seek to mislead or improperly or illegally avoid the payment of import duties, taxes and fees, and never engage in activities meant to evade the legal requirements of international traffic and trade.
Know with whom you are dealing and must not engage in or facilitate business with entities or any other individuals specifically prohibited by law, including without limitation the USA PATRIOT Act and all Anti-Terror Legislation. Furthermore, be aware of, and comply with, restrictions on dealing with entities and individuals located in countries that are subject to trade embargoes or economic sanctions imposed by the United States and other countries where we do business.

Commitment to Business Partners
The Company’s relationships with its Business Partners must be characterized by honesty and fairness. We are guided by the following standards of behavior:

• We will not make payments to any employees of Business Partners to attain lower prices or additional business.
• We will not reveal a Business Partner’s pricing, technology or other confidential information without prior written permission.
• We will not make false or misleading remarks to others about Business Partners or their products or services.
• We will hold our Business Partners to the same standards and expectations to which we hold our own operations and employees.

Resolving Code of Conduct or Ethics Issues

Employees of Business Partners are encouraged to work through their own company to resolve internal ethics issues. However, Business Partners should promptly report violations of this Code or any unethical behavior by an employee of the Company to [email protected]