CONFIDENTIAL

Marsh USA Inc

Broadcast on Privacy Protocol

Pursuant to the requirements of the Gramm-Leach-Bliley Act ("GLBA"), Marsh has developed privacy notices describing the nature of private client information that we may receive and the circumstances under which we may share that information with third parties. GLBA requires that this notice be sent to (1) all clients annually and when the notice is revised and (2) new clients when the client relationship is established. Each client executive is responsible for complying with the following Privacy Protocol:

Existing Clients

All clients must be mailed a copy of the Marsh privacy notice on an annual basis and also whenever the notice is revised. The annual notice should be mailed on May 15th of the current year. The notice should be mailed even if the client became one during the January through May period and was sent a notice under the New Clients procedure described below.

Clients in the Model Act states (Arizona, California, Connecticut, Georgia, Illinois, Kansas, Maine, Massachusetts, Minnesota, Oregon, Nevada, New Jersey, North Carolina, Ohio, and Virginia) should receive the Model Act GLBA Notice.

Clients in all other states should receive the Model Regulation GLBA Notice.

New Clients

All new clients must be sent a copy of the privacy notice when the customer relationship is established. It is recommended that notice be provided to the client immediately if initial contact with the client is in person, or if not in person, mailed with the first piece of correspondence sent to the new client. In any event, the notice must be sent not later than:

(1)  The time when personally identifiable information is collected from a source other than the individual client him- or herself or from public records (for example, when a credit report or MVR is ordered through a private agency); or,

(2)  Ten (10) days after the first to occur of:

(a)  The client's execution of a broker of record letter, client service agreement, consulting agreement or similar engagement agreement;

(b)  The creation of a billing code or customer number for that client;

(c)  The first invoice is sent to that client.

Responsibility

It is the responsibility of the client executive to make sure that the privacy notice is sent to existing and new clients. The above procedure is a professional standard subject to compliance review. Client files must be annotated to record the sending of initial, annual, and revised privacy notices.

The information contained in this document is confidential, may be privileged, and is intended for the use of the individual or entity named above. If you, the reader of this document, are not the intended recipient, the agent, or employee responsible for delivering this document to the intended recipient, you are expressly prohibited from copying, disseminating, distributing, or in any other way using any of the information contained in this document.