Disclosures

OVERVIEW

Martinson & Company, Ltd. (Martinson) is committed to ensuring the confidentiality of each client’s non-public personal information. As you are aware, the financial services business involves access to the most intimate financial and business details. In order to maintain a relationship that is based upon trust and confidentiality, you will be provided with a Client Privacy Notice annually.

The types of non-public personal information that clients provide to us in order for us to provide services may include, but is not limited to: name, address, social security number, total assets, net worth, income, and bank account information. This policy addresses what Martinson does with this information both with respect to related and non-related third parties. For purposes of this document, issuers of securities for whom we act as an underwriter or selling agent are considered non-related entities. Also, at this time, Martinson has no related third-party affiliates.

Except as required by law, Martinson generally does not disclose any non-public personal information about our clients or former clients to any person or entity not directly affiliated with our firm. However, we may disclose non-public information that we collect to the issuer(s) of the securities that clients ask to purchase or we may share some non-public information of an issuer with a client who is considering purchasing an interest in its business, etc.

Also, we may share some information such as names and addresses to non-affiliated entities to enable them to provide business services on our behalf. Examples of these services are assisting us in mailing sales literature, processing a transaction, and performing general administrative activities for us. These types of services sometimes are necessary in order for us to conduct business. However, rest assured that any service provider that we do business with is contractually obligated to ensure that none of your personal information will be disclosed, except as required by law.

In order to assure that all non-public information is treated in a confidential manner, our employees are required to protect the confidentiality of our clients’ information. If they do not comply with our policies, employees are subject to disciplinary rules. Also we maintain physical, electronic, and procedural safeguards to protect all non-public information.

Opt-Out Policy: As we will not be sharing any non-public information either with related or non-related third parties, unless necessary to facilitate a transaction, an opt-out provision is not available. If you have any questions regarding our Privacy Policy, please contact us immediately at (952) 473-4133.

BUSINESS CONTINUITY PLAN DISCLOSURE STATEMENT

Martinson & Company, Ltd. (Martinson) has developed a Business Continuity Plan describing how we will respond to events that significantly disrupt our business. With that in mind, we are providing you a condensed summary of our business continuity plan on our web site. The full summary is provided to all clients and is available upon request.

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, or the whole Minneapolis/St. Paul region. Depending on the type of disruption, we will transfer our operations to a site outside of the affected area, and recover and resume business as soon as possible.

In either situation, we plan to continue in business and notify you through our web site www.martinson.net or our main telephone number: (952) 473-4133. If the significant business disruption is so severe that it prevents us from remaining in business, we will assist you in contacting parties you have conducted business with (issuers and investors).