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Legal Notices and Further Information
on Diamant Asset Management Inc. and Diamant Investment Corporation

For disclosure of SEC required order execution and order routing information on Diamant Investment Corporation, click here.

All information contained herein is for informational purposes only and does not constitute a solicitation or offer to sell securities or investment advisory services. Such an offer can only be made in states where the investment advisor and/or the broker/dealer is registered or where an exemption from such registration is available, and no new account will be accepted unless and until all local regulations have been satisfied. Both firms and their agents may only transact business in states they are registered in, unless exclusion or exemptions apply from state registration. Responses that involve either the effecting or attempting to effect securities transactions, or the rendering of personalized investment advice to persons will not be made absent compliance with state registration requirements or an applicable exemption or exclusion.

This presentation does not purport to be a complete description of our performance or investment services. It is not our intention to state or imply in any manner that past results and profitability is an indication of future performance. The information contained herein was obtained from sources which we believe to be reliable, but we do not guarantee its accuracy. Our corporations, or their officers, directors, or stockholders or members of their families may at times have a position in the securities mentioned herein and may make purchases or sales of these securities from time to time in the open market.

Privacy Policy Notice. Both Diamant Asset Management Inc. and Diamant Investment Corporation maintain complete privacy on information provided by our customers. Each firm has written procedures to insure privacy of information. The following disclosure statement is required for Diamant Investment Corporation:

One of our firm’s greatest assets has been the emphasis on maintaining complete privacy on information provided by our customers. Our firm is a self-clearing broker/dealer, which means all information is contained on our premises. This information is shared with our affiliated registered investment advisor, Diamant Asset Management, Inc., to maintain client portfolios and provide investment advice. We treat the information we gather about you in a confidential manner. We maintain physical, electronic and procedural safeguards that insure the safety of customer information. We restrict access to your personal and account information to those employees who need to know that information to provide products or services to you. This data may be non-public personal, financial information about you that we collect directly from you or from other sources. We collect information from our forms, including our application form and transactions with our firm or others. Such information may include personal information such as name and address, and financial information such as your income and assets. It is our policy not to disclose any nonpublic personal information about you to Anyone not described in this notice, except as permitted by law. Further, we do not share any personal information with other companies for marketing purposes. If you decide to close your account(s) or become an inactive customer, we will adhere to the privacy policies and practices as described in this notice.
Business Continuity Plan. Both Diamant Asset Management Inc. and Diamant Investment Corporation share the same office space, share employee and equipment resources, and service client accounts that are customers of both firms. Due to this affiliation between these firms, the established Business Continuity Plan includes both entities. The following disclosure statement is required for Diamant Investment Corporation:
Diamant Investment Corporation has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us – If after a significant business disruption you cannot contact us as you usually do at 203-661-6410, you should call our alternative numbers 800-342-4255 or 203-938-3316, or go to our web site at www.portfolioadvisor.com . After restoring communication after a significant business disruption event , we will be available to handle the usual and customary client services, including provide prompt access to funds and securities, entering of orders and processing of other trade-related, cash, and security transfer transactions.

Our Business Continuity Plan – 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.

Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

We back up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, our objective is to restore operations and be able to complete existing transactions and accept new transactions and payments within the same business day. Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within the same business day. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within the same business day. In either situation, we plan to continue in business, and notify you through our web site www.portfolioadvisor.com or our customer emergency numbers 800-342-4255 or 203-938-3316, how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

For more information – If you have questions about our business continuity planning, you can contact us at 203-661-6410 or at herb@portfolioadvisor.com.

Use of Client Commissions: Clients have authorized Diamant Asset Management, Inc. to use our affiliated broker/dealer to hold securities and handle security transactions. Our overall investment philosophy generally results in a low portfolio turnover rate, excepting a possible reallocation of existing securities into new securities to meet a clients changing needs. Over the years of a client relationship, with low transaction volume, commission dollars per account are not substantial in nature in relation to the size of the overall account. The use of commission dollars includes rapid access to the marketplace, access to live market information, the costs of custody and safekeeping functions, handling customer disbursement needs, year end tax reporting, accessing research, and the providing of current account information both to the investment advisor and to the portfolio accounting system. In consideration for such services, we recognize that any commission charged by our affiliate on a transaction may be more or less than the commission charged to or by others in similar transactions. Inherent to the bond business, this affiliated broker/dealer may be compensated for their expertise in locating bonds in the form of markups or markdowns to the market. Such bond compensation may be smaller than or in excess of compensation for equity transactions.

Proxy voting policies. It is the policy of Diamant Asset Management, Inc. that when we exercise voting authority over client proxies, the proxies are voted in the best interests of the clients. We shall exercise the duties of care and loyalty when voting proxies. The duty of care requires us to monitor corporate events and to vote the proxies. This duty of care does not mean that failure to vote on every proxy would necessarily violate our fiduciary obligations. To satisfy its duty of loyalty, we must cast the proxy votes in a manner consistent with the best interest of its client and must not subrogate client interests to our own. Upon receipt of a written request directly from a client, we shall provide records of proxy voting information with respect to the particular client’s holdings. On receipt of a written request from a client, we shall provide a copy of our voting policies and procedures.

Diamant Asset Management Inc. or Diamant Investment Corporation may revise these terms and this Web site at any time by updating this posting. You should visit this page from time to time to review the then current terms because they are binding as posted on a particular date.

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