A Commitment to Your Privacy

Effective July 1, 2008

At The Charles Schwab Corporation and its affiliates and subsidiaries ("Schwab"), our most important a sset is our relationship with you. We are honored that we have been entrusted with your financial affairs, and we are committed to protecting the privacy of information we maintain about you. Establishing and adhering to an effective privacy policy regarding proper handling and use of information about you is an important part of that dedication.

Below, you will find details about Schwab's commitment to protecting your privacy, including the types of information we collect about you, how we use and share that information both within and outside the Schwab family of companies, and how you can instruct us to limit certain types of information sharing. Our privacy policy applies to you as a participant in a retirement or other employee benefit plan serviced by Schwab.

Your Privacy Is Not for Sale

Simply put, we do not and will not sell your personal information to anyone, for any reason, at any time.

How We Collect Information About You

We collect personal information about you in a number of ways.

• Application and enrollment information. We collect information from your employer when a retirement or other employee benefit plan is serviced by Schwab. We collect account application and enrollment information from you directly when you enroll in the plan or initiate account transactions or otherwise request services from Schwab. You will also be asked for information when you choose to participate in a Schwab promotion. We may also collect information from consumer reporting agencies to verify your identity in the account-opening process or if you apply for other financial products or services. The information we collect may include personal information, such as your name, address, phone number, email address, Social Security number, date of birth, and employee data from your employer regarding your enrollment and participation in the plan, as well as details about your interests, investments and investment experience.
• Transaction and experience information. Once an employer has established a plan account with us, we collect and maintain personal information about your account activity, including your transactions, balances, positions and history. This information allows us to provide the services you or the employer have requested.
• Third-party information providers. We may collect information about you from information services and consumer reporting agencies to verify your identity, employment or creditworthiness, or to better understand your financial needs.
• Website usage. When you visit our website, our systems may use devices known as "cookies," graphic interchange formats files (GIFs), or other similar web tools to enhance your web experience. These tools enable us to recognize you when you return to our site, maintain your web session while you browse, as well as help us provide you with a better, more personalized experience at Schwab. To learn more about our policies regarding using our website and the use of web tools, please visit https://www.401kaccess.com/privacy.

How We Share and Use Information About You Within the Schwab Family of Companies

The term "Schwab" refers to the family of financial services companies that are owned by The Charles Schwab Corporation. These companies are often referred to as "affiliates" and include, but are not limited to:

Schwab Retirement Plan Services, Inc.
The 401(k) Companies, Inc.
Charles Schwab & Co., Inc., a broker-dealer
Charles Schwab Bank, a retail bank
Charles Schwab Trust Company, a division of
Charles Schwab Bank
Charles Schwab, Hong Kong, Limited
Charles Schwab, U.K., Limited

Many employers and plan participants do business with more than one Schwab affiliate, creating an efficient, comprehensive financial relationship to meet individual needs. When appropriate, Schwab may share information we collect about you within our family of companies to:

• help provide you with better service or perform services on our behalf;
• respond to communications from you (or as you authorize or request);
• make it more convenient for you to open a new account or provide other services to you.

Schwab may also allow an affiliate to provide you with information about its products and services that we believe may benefit or interest you.

You may instruct Schwab not to share information about you with our affiliates for certain purposes, as explained under "How to Limit the Sharing and Use of Information About You."

How We Share Information About You Outside of the Schwab Family of Companies

We provide access to information about you to outside companies and other third parties in certain limited circumstances, including:

• to help us process transactions for your account;
• when we use another company to provide services for us, such as printing and mailing your account statements;
• when we believe that disclosure is required or permitted under law. For example, we may be required to disclose personal information to cooperate with regulatory or law enforcement authorities, to resolve consumer disputes, to perform credit/authentication checks, or for risk control.

Schwab may also enter into a joint-marketing agreement with another financial institution in order to provide you with a Schwab-branded financial product or service. We only make such agreements with companies that we believe can help us provide a financial product or service that will benefit you.

You may instruct us not to share information about you with outside companies for this purpose, as explained under "How to Limit the Sharing and Use of Information About You."

How to Limit the Sharing and Use of Information About You

If you prefer, you may choose to limit the information we share about you among our affiliates and outside companies for marketing purposes. If you choose to do so, Schwab will not:

• share among our affiliates consumer reports and other personal information about you that may be used to determine your eligibility for credit (for example, information about your income, profession or employment status);
• allow our affiliates to market their financial products or services to you based on eligibility information they receive from us;
• share personal information about you with an outside company for joint-marketing purposes.

You may exercise this choice by calling us at 1-800-777-4015.

• Your choice will be applied to you as an individual participant in the employer's plan account and will automatically be extended to any accounts you open at Schwab.
• If in addition to the plan account, you establish a joint brokerage or banking account, you may instruct us on behalf of another account holder but only in relation to the joint account.
• You may make your privacy choice at any time, and it will remain in effect until you tell Schwab to change it. If you have previously given Schwab your privacy choice with respect to your current accounts, you do not need to provide it again.

If you exercise your privacy choice, Schwab will continue to share information that identifies you (such as your name and Social Security number), as well as information about your transactions and experiences with us. In addition, Schwab affiliates may continue to use information about you to perform servicing related to your accounts and to respond to communications from you, if you authorize or request, or, if you are their customer, to offer you products or services. We may also continue to share information about you with outside companies as permitted or required by law.

Company Mailing Choice

Unless we receive your objection, Schwab may be required under the provisions of Rule 14b-1 of the U.S. Securities and Exchange Act of 1934 to release your name, address and number of shares to the issuers of securities you hold. If you object, you will not receive any corporate communications mailed out by the issuer other than regulatory mailings required to be sent out to all holders, which you will receive from us. If you wish to exercise this preference, please contact Participant Services at 1-800-777-4015.

State Laws

Schwab will comply with state laws that apply to the disclosure or use of information about you. For example, if your address is in Vermont, we will automatically limit information sharing as described in "How to Limit the Sharing of Information About You" without your having to advise us of this privacy choice.

The following notice is required to be made under Nevada law to all customers with a Nevada mailing address. At any time, you may request to be placed on our internal "do not call" list. You may do so by calling at 1-800-777-4015. Customers from any state may request to be placed on Schwab's internal "do not call" list by calling 1-800-777-4015. If you would like further information about this notice, you may contact us at P.O. Box 684067, Austin, Texas 78768-4067 or at 1-800-777-4015. Email us at partserv@401kaccess.com.

For more information about the Nevada "do not call" notice requirement, you may also contact the Nevada Attorney General, 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; phone 702-486-3132; email BCPINFO@ag.state.nv.us.

Safeguarding Your Information, Maintaining Your Trust

We take precautions to ensure the information we collect about you is protected and is accessed only by authorized individuals or organizations. Companies we use to provide support services are not allowed to use information about our clients for their own purposes and are contractually obligated to maintain strict confidentiality. We limit their use of information to the performance of the specific services we have requested.

We restrict access to personal information by our employees and agents. Our employees are trained about privacy and are required to safeguard personal information. We maintain physical, electronic and procedural safeguards to protect personal information.

Teaming Up Against Identity Theft

Identity theft is a serious concern to all of us. Safeguarding information to help protect you from identity theft is a priority at Schwab. We're committed to keeping your personal and financial information safe online. To enhance your security, Schwab takes steps to protect you from identity theft by:

• Utilizing identification and authentication procedures before initiating transactions;
• Using firewalls and encryption technology to protect personal information on our computer systems;
• Creating a secure transmission connection to our Schwab websites. You will see a key or closed padlock in the browser's status bar indicating it is a secure site. In other browsers, look for the address bar to turn green;
• Training our employees on privacy and security to properly handle personal information about you.

You can also help protect your identity and accounts.

Here are a few steps to remember:

• When using the Internet, keep your login ID and password confidential;
• Keep your security software up-to-date and turned on;
• Shred documents that contain personal information;
• Check your credit report regularly for unauthorized activity and protect your personal identification numbers (PINs) and personal data.

If you suspect fraud or identity theft, the faster you act the better. Contact us at 1-800-777-4015.

Greater Accuracy Means Better Protection

We are committed to keeping accurate, up-to-date records to help ensure the integrity of the information we maintain about you.

A Commitment to Keeping You Informed

We will provide you with advance notice of important changes to our information-sharing practices.

Contact Us with Questions

If you have any questions or concerns, please contact us by email at privacy@schwab.com or call us at 1-800-777-4015.

© 2008 The 401(k) Companies, Inc. All rights reserved. FTA 05067 REG11000KCO (06/08)