We are required by federal law to provide you with a copy of our Privacy Policy annually. The following Policy applies to current and former individual clients who have or had a brokerage and advisory account with Morgan Stanley Smith Barney LLC and those individual clients who are also current and former advisory clients of certain of Morgan Stanley Investment Management’s U.S. investment advisers and to current and former individual investors in certain U.S. mutual funds advised by Morgan Stanley Smith Barney and its affiliates.

This Policy is not applicable to partnerships, corporations, trusts or other non individual clients or account holders, nor is this Policy applicable to individuals who are either beneficiaries of a trust for which we serve as trustee or participants in an employee benefit plan administered or advised by us. This Policy is, however, applicable to individuals who select us to be a custodian of securities or assets in individual retirement accounts, 401(k) accounts, or accounts subject to the Uniform Gifts to Minors Act. Please note that we may amend this Policy at any time, and will inform you of any changes to this Policy as required by law.

We appreciate that you have provided us with your personal financial information and understand your concerns about safeguarding such information. We strive to maintain the privacy of such information while we help you achieve your financial objectives. This Policy describes what nonpublic personal information we collect about you, how we collect it, when we may share it with others, and how others may use it. It discusses the steps you may take to limit our sharing of information about you with affiliated Morgan Stanley Smith Barney companies (“other Morgan Stanley Smith Barney companies”), including but not limited to our global financial services affiliates that are part of our integrated securities and investment management business, and our credit services affiliates. It also discloses how you may limit our affiliates’ use of shared information for marketing purposes.

Throughout this Policy, we refer to the nonpublic information that personally identifies you or your accounts as “personal information.”

To serve you better and manage our business, it is important that we collect and maintain accurate information about you. We obtain this information from applications and other forms you submit to us, from your dealings with us, from consumer reporting agencies, from our websites and from third parties and other sources.

For example:

• We collect information such as your name, address, e-mail address, telephone / fax numbers, assets, income and investment objectives through applications and other forms you submit to us.
• We may obtain information about account balances, your use of account(s) and the types of products and services you prefer to receive from us through your dealings and transactions with us and other sources.
• We may obtain information about your creditworthiness and credit history from consumer reporting agencies.
• We may collect background information from and through third-party vendors to verify representations you have made and to comply with various regulatory requirements.
• If you interact with us through our public and private websites (including ClientServ^SM and ClientLink^SM), we may collect information that you provide directly through online communications (such as an e-mail address) and through interactions with those websites, including the use of “cookies.” Please consult the Terms of Use of these sites for more details.

To provide you with the products and services you request, to serve you better, to manage our business and as otherwise required or permitted by law, we may disclose personal information we collect about you to other Morgan Stanley Smith Barney companies and to nonaffiliated third parties.

a. Information we disclose to other Morgan Stanley Smith Barney companies
In order to manage your account(s) effectively, including servicing and processing your transactions, to let you know about products and services offered by us and other Morgan Stanley Smith Barney companies, to manage our business, and as otherwise required or permitted by law, we may disclose personal information to other Morgan Stanley Smith Barney companies. Offers for products and services from other Morgan Stanley Smith Barney companies are developed under conditions designed to safeguard your personal information.

b. Information we disclose to third parties
We do not disclose personal information that we collect about you to nonaffiliated third parties except to enable them to provide marketing services on our behalf, to perform joint marketing agreements with other financial institutions, and as otherwise required or permitted by law. For example, some instances where we may disclose information about you to third parties include: for servicing and processing transactions, to offer our own products and services, to protect against fraud, for institutional risk control, to respond to judicial process or to perform services on our behalf.

Morgan Stanley Smith Barney recognizes that your relationship with your Financial Advisor is important. If your Financial Advisor’s affiliation with Morgan Stanley Smith Barney ends and he or she joins a nonaffiliated securities broker-dealer with which Morgan Stanley Smith Barney has entered into an agreement limiting the use of information, Morgan Stanley Smith Barney will permit your Financial Advisor to retain certain of your contact information, limited to your name, address, e-mail address, phone number and account title.

When we share personal information with a nonaffiliated third party, they are required to limit their use of personal information to the particular purpose for which it was shared and they are not allowed to share personal information with others except to fulfill that limited purpose.

We maintain physical, electronic and procedural security measures to help safeguard the personal information we collect about you. We have internal policies governing the proper handling of client information. Third parties that provide support or marketing services on our behalf may also receive personal information, and we require them to adhere to confidentiality standards with respect to such information.

We respect your privacy and offer you choices as to whether we share with other Morgan Stanley Smith Barney companies personal information that was collected to determine your eligibility for products and services you request (“eligibility information”). Please note that, even if you direct us not to share eligibility information with other Morgan Stanley Smith Barney companies (“opt-out”), we may still share personal information, including eligibility information, with those companies in circumstances excluded from the opt-out under applicable law, such as to process transactions or to service your account. We may also share certain other types of personal information with other Morgan Stanley Smith Barney companies—such as your name, address, telephone number, e-mail address and account number(s), and information about your transactions and experiences with us.

You may limit other Morgan Stanley Smith Barney companies from marketing their products or services to you based on your personal information that they receive from other Morgan Stanley Smith Barney companies. This information includes your income, assets and account history. Your choice to limit marketing offers from other Morgan Stanley Smith Barney companies will apply until you tell us to change your choice.

If you wish to opt-out of sharing and to limit marketing offers, you may do so by:

• Contacting your Investment Representative
• Calling us toll-free at (877) 636-5937
• Writing to us at the following address:
  Morgan Stanley—Private Wealth Management
  440 S. Lasalle Street
  Chicago, IL 60605
• E-mailing us at usprivacypolicy@morganstanley.com

If you choose to write to us, your written request should include your name, address, telephone number and account number(s) to which the request applies and should not be sent with any other correspondence. In order to process your request, we require that the request be provided by you directly and not through a third party. If you have previously notified us about your privacy preferences, it is not necessary to do so again unless you decide to change your preferences. Your preferences will remain in effect with respect to this Policy (as it may be amended) until you notify us otherwise in writing. If you have a joint account, your direction for us not to share personal information with other Morgan Stanley Smith Barney companies and for those other Morgan Stanley Smith Barney companies not to use your personal information for marketing will be applied to all account holders on that account.

Please understand that if you submit a request, you and any joint account holder(s) may not receive information about Morgan Stanley Smith Barney products and services that could help you manage your financial resources and achieve your investment objectives.

If you hold more than one account with Morgan Stanley Smith Barney, you may receive multiple privacy policies from us, and would need to follow the directions stated in each particular policy for each account you have with us.