Privacy of Non-Public, Confidential or Personal Financial Information

In establishing an advisory account with Sterling Investment Management, Inc., it is necessary that you provide Sterling Investment Management, Inc. with certain personal financial information necessary to ensure that your account is managed in a manner consistent with your investment objectives and personal financial goals. This information will generally be derived from the following sources:

• Information we receive from you
• Information about your securities transactions with Sterling Investment Management, Inc. or other advisors and broker/dealers which may be providing financial services to you.

It is the policy of Sterling Investment Management, Inc. that we do not disclose any non-public personal information about you to anyone, except as permitted by law.
If you decide to close your account(s) with Sterling Investment Management, Inc. or become an inactive client, Sterling Investment Management, Inc. will adhere to the privacy policies and practices as described in this notice.

Sterling Investment Management, Inc. restricts access to your personal and account information to those employees who need to know that information to provide products or services to you. Sterling Investment Management, Inc. maintains physical, electronic, and procedural safeguards to guard your non-public personal information