JOINT NOTICE OF PRIVACY POLICY FOR:
JOHN W. HENRY & COMPANY, INC.
WESTPORT CAPITAL MANAGEMENT CORPORATION
GLOBAL CAPITAL MANAGEMENT LIMITED
JWH INVESTMENT MANAGEMENT, INC.
JWH SECURITIES, INC.

The following policies contained in this notice are applicable with respect to customers of John W. Henry & Company, Inc. ("JWH"), a registered commodity trading advisor and commodity pool operator, Westport Capital Management Corporation ("WCM"), a registered commodity pool operator, Global Capital Management Limited ("GCM"), a registered commodity pool operator, and JWH Securities Inc. ("JWHSI"), a registered broker-dealer (collectively the "JWH Companies" or "Affiliates").  

This notice is provided to you as a customer of the JWH Companies, pursuant to the Commodity Futures Trading Commission's adoption of rules regarding the Privacy of Consumer Financial Information and/or the U.S. Securities & Exchange Commission's adoption of Regulation S-P, entitled "Privacy of Consumer, in accordance with federal laws related to the privacy of certain information. You become a customer of the JWH Companies when you subscribe and are approved to invest in a fund or account operated or advised by us or when you execute your first investment transaction with us. 

The JWH Companies collect the following categories of nonpublic personal information from its customers: 

Information that you provide to us, about yourself in order to obtain a financial service from us, such as a purchaser questionnaire that enables the JWH Companies to determine if you qualify to invest in an offering or to complete a subscription agreement to invest in an offering. This information would include such items as your name and address, asset and income levels, employment history and past investment experience.

Information about your transactions with our Affiliates, such as information related to your investment in a pool operated by us or introduced and/or advised by us. This information would include such items as the parties to investments you make though the JWH Companies, the size of those investments, and the programs you invest in.  

The existence of your customer relationships with any of the JWH Companies is considered nonpublic personal information.

All of those types of nonpublic information are disclosed only to the JWH Companies that provide financial services. The JWH Companies are engaged in the business of acting as commodity pool operators and/or commodity trading advisors, or broker-dealers which are each appropriately registered. The Affiliates are related through common ownership. The JWH Companies consists of registered commodity pool operators, WCM, GCM and JWH which operate commodity pools funds that are advised by JWH, which specializes in managing institutional capital in a broad spectrum of worldwide futures and forward markets. Additionally, WCM and JWH operate funds which may be distributed by its broker-dealer Affiliate - JWHSI. The JWH Companies do not provide nonpublic financial information to companies that are not Affiliates. These same disclosure polices apply to former customers of JWH Companies. 

If you close your account or end your customer relationship with us, we will adhere to the privacy policies and practices described within this notice.

The JWH Companies do not disclose any non-public personal information about its customers or former customers to anyone, except as permitted by law without a customer’s express permission. However, we may share a customer's nonpublic personal information in order to: (i) comply with applicable federal, state, local or regulatory laws or valid legal process, (ii) to protect the JWH Companies' rights or property or (iii) when we believe that physical safety is at risk.

We have adopted these policies and practices to protect the confidentiality and security of nonpublic personal information that the JWH Companies obtain from you. Access to that information is restricted to its staff members [and the staff members of its Affiliates] who need to know that information in order to market and sell financial services offered by the JWH Companies. It is also provided to our staff members who need to know that information in order to provide us with services such as accounting and compliance operations of the funds that the JWH Companies operate, as well as to other necessary employees of the Affiliates.  

In addition, the JWH Companies require their staff members with access to your nonpublic personal information to strictly comply with this Privacy Policy. Employees who misuse customer information may be subject to disciplinary action, including but not limited to termination of employment with the JWH Companies. The JWH Companies maintain physical, electronic, and procedural safeguards to guard your non-public personal information.  

The JWH Companies provide this notice to you at the beginning of our relationship with you and annually thereafter in conjunction with mailing of their annual financial statements or year end report.