STRATTON MANAGEMENT COMPANY

PRIVACY STATEMENT

When you hire Stratton Management Company as your investment adviser, you entrust us not only with your hard-earned assets but also with your personal and financial data. We consider your data to be private and confidential, and we hold ourselves to the highest standards of trust and fiduciary duty in their safekeeping and use.

We collect nonpublic personal information about Stratton Management Company advisory clients from the following sources:

• Information we receive from you on new business forms and financial statements;
• Personal information you share with us (name, address, tax id numbers);
• Information about your transactions with us or custodians.

We do not disclose any nonpublic personal information about our clients or former clients to anyone, except as permitted by law. Those exceptions allowed by law include service providers such as securities brokers, transfer agents, and custodians. Additionally, we have a relationship with Chicago Clearing Corporation to handle all securities class action filings for the firm, and with Proxy Edge, an electronic proxy voting service. Moreover, we will not release information about our clients or former clients unless one of the following conditions is met:

• We receive your prior written consent;
• We believe the recipient to be you or your authorized representative;
• We are required by law to release information to the recipient.

We will only use information about you and your account to help us better serve your investment needs or to suggest services that may be of interest to you. If you decide to close your account, we will continue to adhere to the privacy policies and practices described in this notice.

As an additional safeguard, we maintain physical, electronic and procedural safeguards to guard your personal account information. We maintain paper shredding machines in our office, and our employees are trained to destroy nonpublic, personal client information no longer needed for retention in our files. We also restrict access to your personal and financial data to authorized Stratton Management Company employees or any affiliates who have a need for these records.

Our e-mail system has the capability to send and receive messages in an encrypted , protected format. If you wish to communicate with your manager or portfolio assistant via e-mail, please notify them in writing of your preference.

Dated:   August, 2010