Privacy Statement

Martin Capital Management, LLP (“MCM”) recognizes and respects the privacy expectations of its clients. MCM considers clients’ data to be private and confidential, and holds itself to the highest standards of trust and fiduciary duty in their safekeeping and use. MCM has not and will not sell personal information to anyone.

MCM collects nonpublic personal information about clients from the following sources:

• Account Applications and other Forms, which may include a client’s name, address, telephone number, Social Security number, and information about a client’s investment goals and risk tolerance;
• A Client’s Professional Advisors such as consultants, attorneys and accountants, who may provide financial, investment history and tax information about a client;
• Account History, including information about the transactions MCM has ordered and balances in various accounts; and
• Correspondence, written, electronic or telephonic, between a client and MCM or a client’s broker or custodian and MCM.

MCM will not release client account information to any third party unless one of the following conditions is met:

• MCM receives prior client consent;
• MCM believes the recipient to be the client or the client’s authorized representative, including the client’s attorney or accountant;
• The recipient is a broker, custodian or other service provider with whom MCM must share information in order to manage or service a client’s accounts properly;
• MCM is permitted or required by law to release the information to the recipient.

MCM will only use information about a client and a client’s account(s) to:

• Help MCM better serve the client’s investment and financial needs,
• Suggest services or other materials that may be of interest to the client,
• Fulfill our regulatory obligations, and
• Administer MCM’s business.

MCM maintains physical, electronic and procedural safeguards that comply with federal standards to guard the privacy of clients’ nonpublic personal information.

MCM applies the policies and practices described in this notice to both current and former clients.