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Anti-Money Laundering Policy

In 2001, President Bush signed into law Public Law No. 107-56, Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act). This law significantly impacts the financial services industry and providers of electronic communications services and grants law enforcement expanded investigative authority over Client information that may in certain circumstances supercede Gramm-Leach-Bliley Act and Regulation S-P restrictions.

Ceredex has, as a best practice, adopted an Anti-Money Laundering (AML) Compliance Program with which all Ceredex officers and employees are required to comply. Accordingly, Ceredex may, at any time, be required to obtain Client verification and certification of residency. This may include, but is not limited to, obtaining proof of tax identification, individual social security numbers, state or country of residency and birth, passport identification, bank account verifications, and other documentation as required by the federal government and/or other regulatory agencies. Ceredex is restricted from opening and/or maintaining accounts with/through/for shell banks and will immediately cease managing such accounts regardless of when the situation is discovered.

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