We have always been very sensitive to privacy issues and to the ongoing trust our clients, employees and business partners place in us. In respect of your privacy we follow these 10 privacy principles. These principles set standards for how we handle your personal information. In recognition of the sensitive nature of such information, we adhere to strict rules governing the protection of the confidential information.

1. Accountability
We are responsible for maintaining and protecting the personal information we collect, use and disclose. We have designated individuals who are responsible for monitoring our ongoing compliance with the Privacy Principles.

2. Identifying Purpose
We tell you why we need your personal information before or at the time we collect it.

3. Consent
We ask for and receive your consent to collect, use or disclose your personal information. The only exceptions would be in cases where use or disclosure is required or permitted by law, for example in the course of a criminal investigation or medical emergency.

4. Collection Limitation
We only collect information necessary for the purposes we identify to you, and only in a fair and lawful manner.

5. Limiting Use, Disclosure and Retention
We only use the information for the purpose we collect it for, other purposes you consent to, or as required or permitted by law.

6. Accuracy
We take steps to make sure your information is accurate, complete and up-to-date.

7. Safeguards
Personal information shall be protected by security safeguards that are appropriate to the sensitivity of the information, in order to protect your personal information from unwarranted intrusion, release or misuse.

8. Openness
We make information openly available about our privacy policy and practices, through printed material, our Web sites and our Privacy Officer.

9. Individual Access
We provide you with access to any personal information of yours we have, tell you how it is being used, stored and disclosed, and give you the opportunity to request that it be amended, if appropriate and as permitted by law.

10. Security Safeguards
Personal information will be considered confidential, and Global Pacific will establish security safeguards appropriate to the sensitivity of the information to protect that confidentiality. Global Pacific will take the necessary measures to ensure all employees conform to this Privacy Policy. All agents, brokers, plan sponsors and other persons or organizations acting for or on behalf of Global Pacific will be required to comply with this Privacy Policy.