Privacy policy Russell Investments Canada Limited 2009 Russell Investments Canada Limited ("Russell") has always been committed to maintaining the confidentiality, integrity and security of all personal information that we collect, use and maintain in the course of carrying on business. We are proud of our privacy practices and want you to know how we protect this information and use it to service your account. Personal information Personal information means any information about an identifiable individual, including information such as your home address and telephone number, date of birth, age, marital status, religious affiliation, employment history, social insurance number and credit history. However, personal information does not include the name, title or business address or telephone number of an employee of an organization. Collection of personal information Personal information is collected directly from you or through your advisor when you open an account with Russell. This information is obtained by us when you or your advisor sends us a completed application form or when your advisor transmits information to us electronically. In servicing your account, we will also generate personal information, including transaction information. From time to time, we may be required to collect information from a third party who is not your advisor, such as an executor of an estate of a third party who may provide information about you or your account to us. The personal information in your account with us may include your name, birth date, mailing address, social insurance number, phone number(s), account holdings and transactions and the name and address of your beneficiary. Other types of information we may collect and hold in your client account depends on the investment or services you request. At times, we may request independent sources to verify and supplement information that you provide to us. Use of personal information Russell may use your personal information for these stated purposes:   Communicating with you and your advisor and dealer regarding service offering or products which may be of interest to you Establishing and administering your account Ensuring the information in our records is accurate Executing your transactions Meeting legal and regulatory requirements Providing you and your advisor and dealer with account statements and other account related information Providing you with financial statements, tax receipts, proxy mailings, transaction confirmations and other information which may be requested or needed to service your account Setting-up and managing products and services you have requested Verify your identity and protecting against fraud Verifying previously given information when necessary We may also use your information for general research in an effort to enhance our service and product offerings. Disclosure of personal information to third parties Russell discloses your personal information to agents, our vendors or other organizations only for the purposes set out in this Privacy Policy. Third parties who may be provided with your personal information include:   Entities to whom we are legally obliged to provide information Governments, government agencies and regulators Other mutual fund companies, financial institutions and securities dealers when necessary to carry out your instructions such as transferring funds Third parties who perform services for us, such as account statement preparation, mailing, courier deliveries, imaging and document storage Your advisor and dealer At times we may use third parties outside of Canada, including in the United States, to perform services for us involving some of your personal information. This may require transfer of information to those third parties. This information is subject to both the laws of Canada and the laws of the third party's jurisdiction, including laws with respect to disclosure of such information. Often the type of information that we must disclose relates to government tax reporting requirements. We may disclose your information to a third party without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website users or anyone else that could be harmed by such activities. We may disclose user information when we believe in good faith that such disclosure is required by and in accordance with the law. We may also disclose your information in connection with a corporate re-organization, a merger or an amalgamation with another entity, or a sale of all or a substantial portion of our assets. In this case, we would ensure that the information disclosed continues to be used only for the purposes permitted by this Privacy Policy and by the entity acquiring the information. Obtaining/withdrawing consent In providing information to us, directly or through your advisor, and continuing to conduct business with us, you are consenting to the use of your personal information. You may withdraw your consent to our use of your personal information at any time by contacting us at 1-888-509-1792. If you withdraw consent, you may limit the services or products we are able to offer you. In some circumstances, legal requirements may prevent you from withdrawing consent. Updating personal information Russell will provide you with access to your personal information on your written request. Our verification procedures help to minimize risk that such information is released to anyone not authorized to receive it. We will provide you with the requested information within 30 days of receipt of your written request, unless prohibited by law. Except under limited circumstances, you may ask us to amend or update your personal information at any time. Russell reserves the right to charge you for our costs incurred in providing the information requested. Russell may not be able to provide you with full access to your information if:   It contains references to other persons It has been destroyed It is too costly to retrieve It cannot be disclosed for legal or regulatory reasons We would have to disclose proprietary information confidential to Russell or its affiliates If we are unable to provide you with access to your personal information, we will give you an explanation. Protection of personal information We have taken all appropriate measures and put in place controls aimed at safeguarding data. These measures include restricting physical access to our offices and records, passwords and file encryption for on-line activities. Our employees and service providers have access to your personal information only for the purposes set out in this policy to enable them to perform their duties in servicing your account. Retention of personal information We only keep your personal information for as long as it is required (whether to provide you with services or as required by law or regulations). Once it is no longer needed, it is destroyed in accordance with our records management and destruction policies. How long we keep your information depends on the reasons for which it was collected. The type of product or service and the kind of information also affects the length of time we retain information. Your information may be kept even if you are no longer a client with us so long as it is legally necessary for us to have sufficient information to respond to any issues that may arise at a later date. Change of Russell's privacy policy If we find it necessary or desirable to change our Privacy Policy in the future, we will post changes on our website as soon as they go into effect. Any change to this policy will become effective on the date the change is posted on our website. You will be able to clearly see the effective date at the lower left hand corner of this web page. Russell Investments Canada Limited 1 First Canadian Place 100 King Street West Suite 5900, P.O. Box 476 Toronto, Ontario M5X 1E4 Telephone: 416-362-8411 or 888-509-1792 (toll-free) E-mail:canada@russell.com January 1, 2009

Products and services described on these websites are intended for Canadian residents only. Information on these sites should not be considered a solicitation to buy or an offer to sell a security to any person. Persons outside Canada may find more information about products and services available within their jurisdictions by going to Russell's worldwide site, http://www.russell.com.

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