Turner Investment Partners, Inc.

Turner Investment Management LLC

Privacy Policy

At Turner Investment Partners, Inc., your privacy is our priority. your information is shared only in limited ways and for specific purposes. We collect personal information to open your account(s), to process your transaction and to help us provide a better level of service. We do not sell your personal information to anyone. We protect the security and confidentiality of the personal information we collect.

This notice describes the privacy policy followed by Turner regarding:

• How we treat the information we receive about individuals who apply for or obtain our products and services; and
• The third parties with whom we may share this information.

Information Turner Collects
Depending on the nature of your relationship with us, and in order to provide you with individualized service, we must obtain certain information from you. We collect certain nonpublic personal information about you that you provide on applications or other forms (such as your address and social security number), and information about your account transactions with us (such as purchases, sales, and account balances). We may also collect such information through your account inquiries by mail, email or telephone. In all cases, we collect only personal financial information that is either required or necessary to provide personalized financial services to you.

Information Turner Stores
We do not disclose any nonpublic personal information about you to anyone, except as necessary and as permitted by law. Specifically, so that we may continue to offer you products and services that best meet your investing needs, and to effect transactions that you request or authorize, we may disclose the information we collect, as described above, to companies that perform administrative or marketing services on our behalf (such as transfer agents, or printers and mailers that assist us in the distribution of investor or client materials), provided that information relating to clients and customers of the firm that participate in managed account programs shall not be disclosed to companies that perform marketing services. These companies will use this information only for the services for which we hired them, and are not permitted to use or share this information for any other purpose. Their ability to protect the personal financial information of our investors and clients is an important consideration in our relationship with them.

Disclosure of Information about Former Customers
If you decide at some point either to close your account(s) or to become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice.

Protecting Confidentiality and Security
Turner treats information in a confidential manner. Our employees are required to protect the confidentiality of information. With regard to our internal security procedures, we restrict access to your personal and account information to those employees who need to know that information to service your account. Employees are subject to disciplinary rules if they do not comply with our policies. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.

For question about our policy, or for additional copies of this notice, contact Turner Investment Partners, Inc. at 1205 Westlakes Drive, Suite 100, Berwyn, PA 19312, or call (800) 424-4865.

Adopted: January 1, 2003
Last Updated: August 1, 2006