LMCG considers customer privacy to be fundamental to our relationship with our customers. We are committed to maintaining the confidentiality, integrity, and security of our customers’ personal information. It is therefore our policy to respect the privacy of current and former customers and to protect personal information entrusted to us. We have established internal policies to protect customer information, while allowing us to serve our customers’ needs.

Why Are You Receiving This Notice?

This notice describes LMCG’s privacy policy concerning our handling of our customers’ personal information. You are receiving this privacy notice because you are either a customer of LMCG, or are considering becoming our customer. Per Securities and Exchange Commission regulation, we are required to provide to our customers a notice that explains our privacy policy when you open an account and every year that you are our customer.

Safeguarding Privacy

LMCG maintains strict policies and procedures to protect our customers’ personal information. We restrict access to customer information to our employees who require it to provide customers with our services. We maintain physical, electronic and procedural safeguards to protect our customers’ information. We treat the information we gather about our customers in a confidential manner.

Information LMCG Collects About Its Customers

As part of our relationship with our customers, we may collect non-public personal or financial information directly from our customers or from other sources. We also collect information from account applications or other forms. These may include customers’ transactions with LMCG, marketing representatives, financial representatives, private funds, brokers, and financial institutions.

Information collected may include:
• Personal information, such as a customer’s name and address, phone number, e-mail address and social security number
• Financial information, such as income, assets and goals
• Information about a customer’s account or investment with us, such as account holdings and transaction history

How LMCG Handles Its Customers’ Financial Information

As part of servicing or maintaining our relationship with our customer and for other legally permitted or required purposes or as requested by any governmental agency or authority or to the extent reasonably necessary to prevent fraud and unauthorized transactions, LMCG may disclose your non-public personal and financial information, if applicable. This may include providing such information to service providers working with us to complete a transaction, to your custodian or consultant, and to your marketing representative, financial representative, private fund, broker or financial institution, to service your account or investment.

Unless specifically authorized in writing, we do not share our customer’s personal information with other companies not affiliated with us for marketing purposes. To further illustrate our commitment to our customers, we will not share personal information with our affiliates unless the customer requests or consents to the sharing (“opt-in”).

Even after your account with LMCG has terminated, we will continue to protect your personal information and only share that information as permitted and required by law.

Who We Are

For the purposes of this policy, “LMCG” includes LMCG Investments, LLC, any subsidiaries it may have from time to time, and any private investment funds sponsored by any of them from time to time. LMCG is affiliated with Royal Bank of Canada. LMCG operates independently of RBC and of the various investment advisors and broker-dealers with which LMCG is affiliated through RBC.

For questions concerning this policy, please contact us in writing to:

LMCG Investments, LLC
Compliance Office
200 Clarendon Street, 28th Floor
Boston, MA 02116