At Johnson Investment Counsel, Inc., we work hard to earn the trust of our clients and everyone with whom we deal. The relationship between Johnson Investment Counsel, Inc., our affiliates, and our clients is the most important asset of our firm. We strive to maintain your trust and confidence, which is an essential aspect of our commitment to protect your personal information to the best of our ability. We believe that our clients value their privacy, and we do not disclose your personal information to anyone unless it is required by law, at your direction, or is necessary to provide you with our services. We have not and will not sell your personal information to anyone.

Johnson Investment Counsel and our affiliates collect and maintain your nonpublic personal information so that we can better provide investment management and trust services. The types and categories of information that we collect and maintain about you include:

• Information we receive from you to open an account or provide investment advice and trust services, such as your home address, telephone number, and financial information
• Information about your tranbsactions that we need to service your account, such as trade confirmations, account statements, and other financial information

In order for us to provide investment management and trust services to you, it is sometimes necessary for us to disclose your personal information to third parties (e.g., brokers, custodians, regulators, and tax return preparers). In addition we also outsource certain functions to various nonaffiliated third-party vendors. To allow these vendors to perform their contracted services, the firm may disclose certain nonpublic personal information about its clients to these vendors. While our contractual arrangements with third-party vendors prohibits third-party vendors from disclosing or using client information other than for the purposes of performing services for the firm, third-party vendors could experience information security breaches or other incidents that could expose client information. The occurrence of such an incident at a third-party vendor is outside of the firm’s control.

To fulfill our privacy commitment at Johnson Investment Counsel, we have instituted firm-wide practices to safeguard the information that we maintain about you. These include:

• Adopting procedures that put in place physical, electronic, and other safeguards to keep your personal information safe
• Limiting access to personal information to those employees who need to know that information to perform their job duties or provide products or services to you
• Requiring third parties that perform services for us to agree, by contract, to keep your information strictly confidential
• Protecting information of our former clients to the same extent as our current clients

At Johnson Investment Counsel, we value your privacy.

If you have any questions, please feel free to contact us.