1. Anti-Money Laundering

It is the policy of Starlight to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler's checks, or deposited into accounts at financial institutions. At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

Goals of Starlight's AML Program

The anti-money laundering program will;

• Establish and implement policies and procedures that can reasonably detect and cause the reporting of transactions as required by the rules and regulations listed below;

• Establish and implement policies, procedures and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act;

• Provide for independent testing for compliance to be conducted by Company personnel or qualified outside parties;

• Designate an individual responsible for implementing and monitoring the day-to-day operations and internal controls of the program; and

• Provide ongoing training for personnel.

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2. Privacy Pledge

Starlight respects your right to privacy. We have always been committed to secure the confidentiality and integrity of your personal information. We are proud of our privacy practices and want our current and prospective customers to understand what information we collect and how we use it.

Why We Collect Your Information

We gather information about you and your accounts so that we can (i) know who you are and thereby prevent unauthorized access to your information, (ii) design and improve the products and services we offer and (iii) comply with the laws and regulations that govern us.

What Information We Collect

We may collect the following types of ‘nonpublic personal information' about you:

• Information about your identity, such as your name, address and social security number;

• Information about your transactions with us;

• Information we receive from you on applications, such as your finances or employment.

What Sources We Obtain Your Information

We collect nonpublic personal information about Starlight clients such as you from the following sources:

• Information we receive from you on applications or other forms; and

• Information about your transactions with us, or others.

What Information We Disclose

We do not disclose any nonpublic personal information about our customers or former customers to anyone, except as permitted by law. Moreover, we will not release information about our customers or former customers 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 only use information about you and your account to help us better serve your investment needs or to suggest services or educational materials that may be of interest to you.

Confidentiality and Security

We maintain physical, electronic and procedural safeguards to guard your personal account information. We also restrict access to your personal and financial data to authorized Starlight associates who have a need for these records. We require all nonaffiliated organizations to conform to our privacy standards and are contractually obligated to keep the information provided confidential and used as requested. Furthermore, we will continue to adhere to the privacy policies and practices described in this notice even after your account is closed or becomes inactive.

We will continue to conduct our business in a manner that conforms with our pledge to you, your expectations and all applicable laws.

3. Business Continuity Plan

Starlight has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions are unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us

If after a significant business disruption you cannot contact us as you usually do at (510) 527-6954 or mfroikin@starlightinvestments.com then you should contact the entities that you have invested in directly for instructions on how you may access investment information, invest additional funds and or provide you with prompt access to funds and securities.

Our Business Continuity Plan

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm's books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. Our business continuity plan addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their investments if we are unable to continue our business.

Since you invest directly, the entities that you have invested in are responsible for those records they maintain on your behalf. Additionally, when you invest with our assistance, we take steps to assure that you have paper or electronic copies of everything that you have signed and or obligated your self to, which results in your having access to essentially the same records as we have, should you be unable to contact us during an emergency situation. Finally, while most transactions done through us are not time sensitive, every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption. Thus, while each entity with which you have invested desires to restore its own operations, to be able to complete existing transactions and to accept new transactions and payments within a short period of time, your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within 2 business days. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within 5 business days. In either situation, we plan to continue in business, and notify you through our web site www.starlightinvestments.com how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer's prompt interface with the respective companies and entities that have provided investment products to you, through us.

Contacts:

Alan Davis

CEO and Managing Director

1307 Bonita Ave, Suite 100

Berkeley, CA 94709

alan@starlightinvestments.com

Tel: 510-501-9314

Murray Froikin

COO and Managing Principal

235 East 50th Street, Suite 57

New York, NY 10022

MFroikin@starlightinvestments.com

Tel: 646-644-8760