Privacy Statement

Important Notice for harbert.net

PRIVACY STATEMENT

The HMC internet website may occasionally use a “cookie” in order to provide better service, to facilitate your use of the website, to track usage of the website, and to address security hazards. A cookie is a small piece of information that a website stores on your PC and which it can later retrieve. We may use cookies for some administrative purposes; for example, to store your preferences for certain kinds of information. None will contain information that will enable anyone to contact you via telephone, e-mail, or any other means. If you are uncomfortable with the use of cookie technology, you can set your browser to refuse cookies.

The terms HMC, we, our and us, when used in this notice, mean Harbert Management Corporation and certain of its affiliates.

As permitted by law and as outlined in this Privacy Notice our policies and procedures for collecting and disclosing personal, non-public information are as follows:

We may collect non-public, personal information about our investrs (“you”) from:

Conversations we have with you to discuss your interest in the financial services and products that are offered through us;

Forms that we obtain from you to determine whether you are eligible to invest through us (“Eligibility Information”);

Your investments in an HMC sponsored investment fund; and

Other contacts and transactions you have with us or our affiliates,

HMC protects the confidentiality of such Eligibility Information and, except as provided below, limits its availability to our employees who need to know such information. We maintain physical, electronic and procedural safeguards that are designed to comply with applicable regulatory standards to guard your non-public, personal information. Furthermore, we take reasonable steps to ensure that all information is kept secure and protected against unauthorized use and is maintained only for the purpose for which it is intended.

To the extent permitted by law, we may share Eligibility Information, as well any of the other information described above, with non-affiliated service providers such as lawyers and accountants, affiliates who may provide services to HMC sponsored investment funds, or to affiliates who market and solicit interests in HMC sponsored investment funds. These service providers and affiliates are, or will be, under a duty of confidentiality with respect to such information. Further, to the extent required by law, we may share Eligibility Information with certain governement or regulatory entities.

Otherwise, we do not disclose any of the non-public, personal information we collect except potentially: (i) your name, (ii) the fact that you have invested with us and (iii) the amount of your investment. These facts may be shared with other prospective investors who wish to know the identity of current or former HMC investment partners or to persons that consult with or recommend such prospective investors.

If you have any questions or comments about this Privacy Statement or the use of your information, please contact us at irelations@harbert.net.

Last Updated: 01/15/2013