January 2009

Burnham Financial Group honors your relationship with us, and we respect the confidentiality and security of your private personal and financial information. Our Privacy Policy is in place to protect your information while serving your investment needs.

We ask for personal information about you when you open an account with our firm. This information may include your name, address, social security number, account statements, and information from third parties such as other banks or brokerage firms, accountants and attorneys. We use this information to evaluate and serve your financial needs, to fulfill your investment requests and complete your transactions.

Burnham Asset Management Corp. and Burnham Securities Inc. contract with other firms in order to provide you with a full range of services, and we may share aspects of your personal information in the course of conducting your business. For accounts at Burnham Securities Inc., this includes our clearing firm, J.P. Morgan Clearing Corp., and other firms with whom we may trade securities on your behalf. For Burnham Asset Management, this may include Burnham Securities and J.P. Morgan Clearing Corp., or other brokerage concerns, plus outside custodial agents as you may direct. We will not sell, market or otherwise disclose any information about you or your account to any third party or individual.

In order to service your account, we may need to work with unaffiliated parties for services such as account maintenance or administration. We maintain strict guidelines reflecting their business standards and their privacy policies. We also restrict access to your nonpublic, personal information to those employees, agents and parties who need to know the information in order to process your transactions or supervise your account. If you ask us to provide information to one of your agents, for example your accountant or attorney, we will honor that request. Our industry is regulated, and at times we are obliged to disclose information during routine audits by U.S. government regulators, the Financial Industry Regulatory Authority (FINRA), or other official regulatory agencies. The purpose of these audits is to review our firms’ compliance with the rules and regulations of our industry, to detect fraud or unauthorized transactions, or to comply with a court order.

We also maintain safeguards that comply with federal and technological standards to safeguard your data. We regularly evaluate and update our systems to ensure the highest levels of security.

If you have any questions, please do not hesitate to contact your account representative.

 
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For more information on any Burnham fund, please request a free prospectus from your financial advisor, call Burnham Funds at (800) 874-FUND, or click here to download a prospectus. An investor should consider the investment objectives, risks, charges, and expenses of an investment carefully before investing. The prospectus contains this and other information. Read it carefully before you invest or send money.

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