Barrett Capital Management, LLC, an independent Registered Investment Advisory firm, is committed to safeguarding the confidential information of its clients. We hold all personal information provided to our firm in the strictest confidence. These records include all personal information that we collect from you in connection with any of the services provided by Barrett Capital Management, LLC. We will not disclose information to nonaffiliated third parties, except as permitted by law. As you know, we use financial information that you provide to us to help you meet your personal financial goals while guarding against any real or perceived infringements of your rights of privacy. Our policy with respect to personal information about you is listed below:

• The categories of nonpublic personal information that we collect from a client depend upon the scope of the client engagement. It will include information about your personal finances, information about transactions between you and third parties, and information from consumer reporting agencies.
• We limit employee and agent access to information only to those who have a business or professional reason for knowing, and only to nonaffiliated parties as permitted by law. (For example, federal regulations permit us to share a limited amount of information about you with a brokerage firm in order to execute securities transactions on your behalf, or so that our firm can discuss your financial situation with your accountant or lawyer.)
• For unaffiliated third parties that require access to your personal information, including financial service companies, consultants, and auditors, we also require strict confidentiality in our agreements with them and expect them to keep this information private. Federal and state regulators also may review firm records as permitted under law. Certain Federal and state laws (such as the USA Patriot Act) may require us at times to disclose certain parts of your personal information to government agencies.
• We do not provide your personally identifiable information to mailing list vendors or solicitors for any purpose.
• We maintain a secure office and computer environment to ensure that your information is not placed at unreasonable risk.
• Personally identifiable information about you will be maintained during the time you are a client, and for the time thereafter that such records are required to be maintained by Federal and state securities laws.
• It is the policy of Barrett Capital Management, LLC not to share nonpublic personal and financial information with affiliated or unaffiliated third parties except under the circumstances noted above.
• We will notify the client and the appropriate Virginia regulatory authorities of any unauthorized access to records that may expose a client’s identity or investments to a third party within three business days of the discovery of the unauthorized access.

By engaging us, or continuing to engage us, for investment advisory services, you consent to the privacy practices described above, including our ability to share your information with unaffiliated third parties for the purposes of providing investment advisory services to you. Should you have any questions regarding our privacy practices, or should you wish to limit or modify our ability to share information with certain third parties, we ask that you please notify us promptly at 804-419-1100 or via email at acrowder@barrettcap.com.