PRIVACY NOTICE

At Wellington Shields & Co., LLC ("WSC"), protecting the privacy of customer information is one of our most fundamental responsibilities. This notice summarizes our policy regarding the confidentiality and disclosure of customer information. We do not sell non-public personal Information to anyone and only share such information with others as stated in this notice.

We take steps to safeguard customer information. We restrict access to your personal and account information to only those employees who need to know that information to provide products or services to you. We emphasize the importance of confidentiality through employee training, operating procedures, and our privacy policy. We also maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your Nonpublic Personal Information. For example, we employ encryption and multi-layer password protected applications. We also use locked file cabinets, password protected computer access and vaults.

We may collect non-public personal information about you from the following sources:

• Your account opening documentation, applications, or other forms (e.g., name, address, phone number, social security number, and date of birth);
• Your transactions with us, our affiliates, or others;
• Information from non-affiliated third parties (e.g., credit history); and
• Information for special services such as bill payment

We may disclose your non-public personal information, as described above, to an affiliated or non-affiliated third party including investment advisors, banks, and broker-dealers to assist us in servicing your account with us. We also may disclose the above information to securities regulators upon request; to others pursuant to subpoena; or as otherwise permitted by law. Even if you decide to close your account(s) or your account becomes inactive, we will continue to adhere to the privacy policies and practices.

• Non-public personal information is personally identifiable financial information that a customer provides to a financial institution; results from a transaction with the customer; or is otherwise obtained by the financial institution. For example, nonpublic personal information includes information regarding your account value and investment history.
• An affiliated third party is any company related or affiliated by common ownership, or affiliated by corporate control or common corporate control, with another company.
• A non-affiliated third party is an entity that is not part of our corporate family.

Safeguarding of customer information is of the utmost importance and should be done only after the approval of the Chief Compliance Officer and under the supervision of a designated person.

WSC shares non-public personal and financial information with affiliated or nonaffiliated third parties under the circumstances noted above. If, at any time in the future, it is necessary to disclose any of client personal information in a way that is inconsistent with this policy, we will give our clients advance notice of the proposed disclosure so that they will have the opportunity to "opt out "of such disclosure. If you have any "opt out" questions please call our Chief Compliance Officer, Christopher Meyer at (212) 320-3080.