Jurisdiction and Intended Audience

This website provides general information about the services provided by Mad River Investors. Mad River is a Delaware Corporation registered with the U.S. Securities and Exchange Commission ("SEC") as an investment advisor pursuant to the Investment Advisors Act of 1940. The advisor may only transact business in any state if it is registered, excluded or exempted from state investment adviser or investment adviser representative registration requirements. Follow-up, individualized responses to persons in any state by the advisor or any representative that involve the rendering of personalized investment advice for compensation will not be made absent compliance with state investment adviser or investment adviser representative registration requirements or an applicable exemption or exclusion.

Nothing on this website should be considered an offer to provide any advisory service in any jurisdiction that would not be lawful in that jurisdiction. The information provided on this website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation, or which would subject Mad River to any registration requirement within such jurisdiction or country. Mad River does not claim that the products or services described in this website are available in any particular jurisdiction or appropriate for any particular investor. If you choose to access this website from a location other than the United States, you do so at your own initiative, and you are responsible for compliance with any applicable local laws.

No Offer or Advice

This website does not constitute an offer to sell or a solicitation of an offer to buy any security that may be referenced on or through this website. Nor does this website constitute an offering or recommendation by Mad River of any security, investment management service, or advisory service. Mad River does not provide investment advice, tax advice, or legal advice through this website, and you agree that this website will not be used by you for such purposes. Mad River does not represent that the securities, products, or services discussed in, or accessible through, this website are suitable for any particular investor. You acknowledge that the provision of any information through this website shall not constitute or be considered investment advice, or an offer to sell, or a solicitation of an offer to buy any security or product.

Investing and General Disclaimers

Inherent in any investment is the potential for loss of capital, past performance is not indicative of future results, and the value of investments and the income derived from investments may increase or decrease. It is not our intention to state, indicate or imply that future investment results will be profitable or equal past results. The information presented is meant to form the basis of a discussion with us and is subject to further clarification and explanation during discussions with us. We do not provide tax or legal advice to our clients, and you are strongly urged to consult a tax or legal advisor regarding any potential investment strategy.

All information and content on this website is subject to applicable statutes and regulations, furnished "as is", without warranty of any kind, expressed or implied, including but not limited to implied warranties of merchantability, fitness for a particular purpose, or non-infringement. Any commentaries, articles or other opinions herein are intended to be general in nature and for current interest. Decisions based on information contained in this website site are the sole responsibility of the visitor. Mad River and its directors, officers, or employees will not be liable or have any responsibility of any kind for any loss or damage that you incur arising from or in connection with:

• Any delay, termination, failure, defect, or interruption in the transmission of this website;

• Any inaccuracy, error, unavailability, or incompleteness in the transmission of this website;

• Any termination or interruption of your access to this website;

• Any other cause relating to your access to or use of this website, whether or not the circumstances giving rise to such cause may have been within the control of Mad River or within the control of any other party providing software or services support for this website.

• All content on this website is presented as of the date published or indicated, and may be superseded by subsequent market events or for other reasons.

This communication may include opinions and forward-looking statements. All statements other than statements of historical fact are opinions and/or forward-looking statements (including words such as “believe,” “estimate,” “anticipate,” “may,” “will,” “should,” and “expect”). Although we believe that the beliefs and expectations discussed are reasonable, we can give no assurance that such beliefs and expectations will prove to be correct. All expressions of opinion are subject to change. You are cautioned not to place undue reliance on these forward-looking statements. Any dated information is published as of its date only. Dated and forward-looking statements speak only as of the date on which they are made. We undertake no obligation to update publicly or revise any dated or forward-looking statements. Investment process, strategies, philosophies, portfolio composition and allocations, security selection criteria and other parameters are current as of the date indicated and are subject to change without prior notice.

Linked Websites

Mad River is not responsible for the content of any site owned by a third party that may be linked to this website via hyperlink. The information to which the user links is neither prepared nor maintained by Mad River, and Mad River has not and will not review or update the information contained in any linked website. Mad River is not responsible for, and makes no warranty with respect to the contents, accuracy, completeness, timeliness, suitability, or reliability of the linked website. Use of any website hyperlinked to or from this website shall be at your own risk. Mad River does not endorse or make any representations about the companies, products, or materials accessible through these hyperlinks. If you opt to hyperlink to other websites accessible through the Mad River website, you do so entirely at your own risk. No representation or warranty is provided for any software that you may download from a link from this website.

Third Party Content

Through this website, you may have access to information relating to securities, indexes or the securities markets ("Market Data"). Mad River may compile or obtain this Market Data from third parties who are independent of Mad River. Even though the sources of the Market Data provided on this website are believed to be reliable, Mad River is not responsible for, and makes no warranty with respect to the contents, accuracy, completeness, timeliness, suitability, or reliability of the Market Data. The Market Data that may be provided is not a complete summary or statement of all available information or data. Any Market Data and other information accessible through this website is for personal, non-commercial use. You agree not to reproduce, modify, sell, distribute, broadcast, publish, or use for any commercial or unlawful purpose any Market Data or other information you access through this website. Any Market Data is provided "as is" and on an "as available" basis. Mad River will not be responsible for lost profits, trading losses, or any other damages resulting from inaccurate, defective, or unavailable Market Data or other information. Mad River is not obligated to update or to continue to offer Market Data or other information accessible through this website.

Electronic Communication

To the extent electronic mail is submitted to this site it should be considered neither secure nor confidential. Mad River makes no representation whatsoever concerning the security or confidentiality of your electronic messages and makes no representation that any electronic messages submitted through this website will be received by Mad River. Delivery, and timely delivery, of electronic mail is not guaranteed. Do not send sensitive or confidential information to us via electronic mail. Mad River therefore recommends that you do not send time sensitive or action-oriented messages to us via electronic mail. Such requests, orders, or instructions will not be processed until Mad River can confirm your instructions or obtain appropriate written documentation where necessary. Furthermore, any communications or material you transmit to Mad River by electronic mail or otherwise, including, but not limited to, data, questions, comments, or suggestions will be treated as nonconfidential and nonproprietary and will become the property of Mad River. Such communications or materials may be used for any purpose, including, but not limited to, reproduction, disclosure, transmission, publication, broadcast and posting. Further, Mad River reserves the right to use any ideas, concepts, know-how, or techniques contained in any electronic communication you send to this website for any purpose whatsoever.

Governing Law and Severability

These Terms will be governed and construed under the laws of the State of Massachusetts. Nothing in these Terms creates any rights or protections that you are not already entitled to by law. If any part of these Terms is held invalid or unenforceable, that part will be deemed modified as necessary to make it effective, and the remaining provisions of these Terms will remain in effect.

Privacy Notice

We do not disclose nonpublic personal information about our clients or former clients to third parties other than as described below.

We collect information about you from our discussions with you, from documents that you may deliver to us and in the course of providing advisory services for you. We may use this information to provide advisory services to you, to open an account for you, to process a transaction for your account or otherwise in the furtherance of our business. In order to service your account and effect your transactions, we may provide your personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information, such as a broker or fund administrator. We may also disclose such information to service providers and financial institutions with which we have joint marketing arrangements. We require third party service providers and any financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. We do not otherwise provide information about you to outside firms, organizations or individuals except to our attorneys, accountants and auditors and as permitted by law.

We restrict access to nonpublic personal information about you to our employees who need to know that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your personal information.

******** (Notated S&P and Performance Disclosure)

Important Disclosure on Model Performance: For the purpose of presenting historical performance information, we reference and present the performance of our Model. While limitations exist with models, we believe our Model offers a reasonable assessment of the typical performance of our historical investment selections for clients. Our Model is based on a taxable portfolio investing since the inception of the investment strategy in March 1999. The Model is presented net of all fees (adjusted to the highest annual fee charged to clients), brokerage expenses, and includes the reinvestment of dividends and interest. The Model generally reflects the performance of portfolios under management since the strategy’s inception in 1999. Client performance will deviate from the Model due to, among other reasons, the starting point of a client relationship; client guidelines, circumstances, and directives; the size of a portfolio and its relative costs; additions and withdrawals of funds; the timing and historical position sizing and concentration of investments; and the account type and its ability to participate in certain investments. During this period there were no strategies employed to obtain the results portrayed other than those implemented for clients pursuant to the Model and disclosed in our Form ADV. Please carefully review our Form ADV for further information. We encourage and strongly recommend that you discuss with us the application, correlation, and significance of the Model’s performance to our client’s historical returns.

Important Disclosure on Benchmark Comparison: The S&P Composite is regarded as a gauge of the US equity market. This index includes a representative sample of 500 leading companies in leading industries of the US economy. Although the S&P 500 focuses on the large-cap segment of the market, we believe it serves as a reasonable proxy for the US market. Nonetheless, the use of the S&P Composite as a comparison may not be appropriate for a variety of reasons including, but not limited to, Model and client account(s) being more concentrated; volatile; holding cash, fixed income investments, and/or option contracts; being short securities; or the average capitalization of companies comprising the Index not correlating with the capitalization of the companies comprising the Model.