Client privacy
policy.

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i. Our commitment to your privacy

Highbrook Capital Partners has a policy of protecting the confidentiality and security of information we collect about our clients. We do not, and will not, share non-public personal information (“Information”) about you with outside third parties without your consent, except for the specific purposes described below. This notice has been provided to you to describe the Information we may gather and the situations under which we may need to share it.

ii. Why we collect and how we use information

We limit the collection and use of Information within our firm to only those individuals associated or employed with us that must have Information to provide financial services to you. Such services include maintaining your accounts, processing transaction requests, and providing the advisory services described in our Form ADV.

iii. How we gather information

All Investment Advisers may need to share personal information to run their everyday business. We get most Information directly from you when you provide us with information from any of the following sources:

• Applications or forms (for example: name, address, social security number, birth date, assets, income, financial history)
• Transactional activity in your account (for example: trading history and account balances)
• Information services and consumer reporting sources (for example: to verify your identity or to assess your credit history)
• Other sources ONLY WITH your consent (for example: your insurance professional, attorney or accountant)

iv. Protecting confidentiality of current and former client’s information

Our employees and affiliated persons are required to protect the confidentiality of Information and to comply with our stated policies. They may access Information only when there is an acceptable reason to do so, such as to service your account or provide you with financial services. Employees who violate our Privacy Policy are subject to disciplinary action, up to and including termination from employment with us. We also maintain physical, electronic and procedural safeguards to protect Information, which comply with applicable SEC, state, and federal laws.

v. Sharing information with other companies permitted under law

We do not disclose Information obtained in the course of our practice except as required or permitted under law. Permitted disclosures include, for instance, providing Information to unrelated third parties who need to know such Information in order to assist us with the provision of services to you. Unrelated third parties may include broker/dealers, mutual fund companies, insurance companies, and the custodian with which your assets are held. In such situations, we stress the confidential nature of Information being shared.

vi. Former customers

Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you, and we will continue to treat your non-public information with strict confidentiality.

vii. Federal & state law allows you to limit sharing — opting out

In the event that Highbrook Capital Partners has a change to its customer privacy policy that would allow it to disclose non-public information not covered under applicable law, Highbrook Capital Partners will allow its clients the opportunity to opt out of such disclosure.

Definitions

• Affiliates: companies related by common ownership or control. They can be financial and non-financial companies.
• Non-affiliates: companies not related by common ownership or control. They can be financial and non-financial companies.
• Joint marketing: a formal agreement between non-affiliated financial companies that together market financial products or services to you.

End of document · HCP / PRIVACY · v 2026-09-30