PRIVACY STATEMENT

The protection of privacy has played a role at Krieger + Associates since our inception in 1988.

The Krieger + Associates Privacy Code is our formal promise to continue to protect the privacy of our clients and the people that they employ. We treat all corporate and client data as highly sensitive and confidential material and work to meet the needs of our clients while maintaining the privacy guaranteed to all individuals.

Supporting our Privacy Code are security guidelines and processes, detailed in our Professional Standards Guide, that are followed as a normal course of business.

Sources of Data — To protect the client and the individual and to competently perform our obligations, Krieger + Associates collects only necessary data from legitimate sources, with legitimate reason and proper authorization.

Use of Data — All requests for data are undertaken with the client's authorization. Information obtained on behalf of our clients is used only for purposes directly related to retained services, is disclosed only to authorized persons for pre-identified reasons, and is securely retained on or off-site for a period that ensures that we can continually meet due diligence to our client.

Safeguarding Data — Krieger + Associates employs multiple means to safeguard client information, including e-mail encryption, locked file drawers, secure delivery, shredding, off-site backup and storage, and strict data management guidelines. In addition, all new staff members are required to sign a confidentiality agreement.

Client Access to Data — Every client for which we conduct business has access to and knowledge of their company's information, including its use and the ability to correct erroneous and incomplete information on demand. Clients are granted full access to their related records and can do so by contacting David Krieger and requesting an in-house meeting.

Accuracy of Data — Before releasing data or advice on any matter, we take all reasonable precautions to ensure that the facts are correct and assumptions properly documented.

K+A Data-Related Procedures — Details of K+A's procedures with respect to confidential information are published in our Professional Standards Guide. K+A's Privacy Code and Professional Standards Guide are available for viewing by any client or individual, and copies are posted on our web site and distributed on paper.

Accountability — All staff share the responsibility of following established procedures and thereby safeguarding client information. The President and Practice Leaders hold accountability for ensuring that the Privacy Code is implemented and upheld.

Challenging Compliance to Privacy Code — In the event of a challenge against our compliance with our Privacy Code or any related legislation, concerns are to be presented in writing to the attention of David Krieger, President.