FIRST PRINCIPLE

Investor Privacy Policy

First Principle is committed to safeguarding confidential information relating to prospective, current and former investors and their representatives. This policy describes the principal ways in which that information may be collected, used and disclosed.

Information we may collect

We may receive non-public personal information through conversations and correspondence, indications of interest, subscription and offering documents, identity and eligibility checks, transaction records, and information supplied by professional advisers, service providers or public registries.

How information may be used

Information may be used to evaluate and manage investor relationships, process subscriptions and transactions, administer investments, maintain records, protect against fraud and comply with legal, regulatory, tax, sanctions and anti-money laundering obligations.

When information may be disclosed

First Principle does not sell personal information or provide it to mailing-list vendors. Information may be disclosed where reasonably necessary to fund administrators, banks, brokers, auditors, lawyers, tax advisers, technology providers and other professional service providers. It may also be disclosed to regulators, tax authorities, courts or law-enforcement bodies where permitted or required by law, or where an investor has authorised the disclosure.

Protection and retention

Access to non-public personal information is restricted to those with a legitimate business or professional need to know it. Reasonable organisational and technical precautions are used to protect information against unauthorised access, loss or misuse. Information is retained only for as long as reasonably necessary for the purposes described above or to meet applicable legal and regulatory requirements.

Further information

Definitive privacy information applicable to an investment will be provided in the relevant offering, subscription or investor materials. Questions concerning this policy may be sent to investor.relations@firstprinciplefund.com.

This policy is provided for general information and may be amended as the structure and operations of First Principle develop. It does not constitute an offer to sell or a solicitation of an offer to buy any security or interest in any fund.

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