Atlas Capital Management (referred to as “ACM”) maintains physical, electronic, and procedural safeguards that comply with federal standards to protect its clients’ non‐public personal information (“information”). Through this policy and its underlying procedures, ACM attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information. It is the policy of ACM to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client. ACM may disclose the client’s information if ACM is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with ACM, (including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker‐dealer, investment adviser, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by ACM in order to facilitate the commencement/continuation/ termination of a business relationship between the client and a non‐affiliated third party service provider (i.e., broker‐dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for ACM (i.e., Investment Management Agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding non‐affiliated third party service provider. ACM permits only authorized employees and affiliates who have signed a copy of ACM’s Privacy Policy to have access to client information. Employees violating ACM’s Privacy Policy will be subject to ACM’s disciplinary process. Additionally, whenever ACM hires other organizations to provide services to ACM’s clients, ACM will require them to sign confidentiality agreements and/or the Privacy Policy. Should you have any questions regarding the above, please contact Jerry Jacobs, Chief Compliance Officer at (260) 637‐2857.


If the client is: (i) a retirement plan (“Plan”) organized under the Employee Retirement Income Security Act of 1974 (“ERISA”); (ii) a participant or beneficiary of a Plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code, with authority to direct the investment of assets in his or her Plan account or to take a distribution; (iii) the beneficial owner of an Individual Retirement Account (“IRA”) acting on behalf of the IRA; or (iv) a Retail Fiduciary with respect to a plan subject to Title I of ERISA or described in section 4975(e)(1)(A) of the Internal Revenue Code: then Atlas Capital represents that it and its representatives are fiduciaries under ERISA or the Internal Revenue Code, or both, with respect to any investment advice provided by Atlas Capital or its representatives or with respect to any investment recommendations regarding an ERISA Plan or participant or beneficiary account.


Our most recent disclosure statement “Brochure” as set forth by Form ADV Part 2 is available upon request or can be immediately viewed (along with other important information) on our website at The Client authorizes the Adviser to deliver, and the Client agrees to accept, all required regulatory notices and disclosures via electronic mail and/or via the Adviser’s internet website, as well as all other correspondence from the Adviser. Adviser shall have completed all delivery requirements upon the forwarding of such document, disclosure, notice and/or correspondence to the Client’s last provided email address (or upon advising the Client via email such document is available on the Advisers web site). It is the Client’s responsibility to notify Adviser of any change to Clients’ email address. Atlas Capital Management continues to manage your investment assets in accordance with your most current designated investment objective(s). Unless and until you advise us otherwise, in writing, we will assume that your investment objectives remain the same; and we shall continue to manage your assets in the same manner as we do currently. As always, please remember to advise us if there are any changes in your personal/ financial situation or investment objectives, or if you wish to impose, add or to modify any reasonable restrictions to our investment management services. Of course, as always, should you have any questions regarding your current objective or any other issue pertaining to your accounts, or any other issue; we will continue to remain available at your convenience to address them either in person at our corporate office or by telephone at (260) 637‐2857.