Privacy Pledge to Customers

We respect your privacy and value the relationship we have with you. Our Privacy Pledge applies to only current or former individual customers who obtain financial products or services from Davenport primarily for personal, family or household purposes. It does not apply to partnerships, corporations, trusts or other non-individual customers, clients, or account holders.

Davenport does not disclose any nonpublic personal information about current or former individual customers as defined above to anyone, except as permitted or required by law. To appropriately service your account(s) and better understand your needs, we collect nonpublic personal information about you from applications, forms you complete, and other information provided by you, whether in writing, in person, by telephone, electronically, or by any other means, such as your name, address, social security number, assets, income and debt. Additionally, we collect information about your transactions with Davenport, such as your account balances, trading activity, payment history, and parties to transactions.

We may disclose the information we collect, as described above, to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements. We have agreements in place with these companies that prohibit them from disclosing or using the information except as necessary for carrying out the purposes for which we disclosed the information.

We also may disclose nonpublic personal information about you to nonaffiliated third parties that assist us in servicing your account(s); to securities regulators as required by laws, rules and other applicable legal requirements; to others pursuant to subpoena; pursuant to your written request, or as otherwise permitted or required by law.

We restrict access to your nonpublic personal information to those employees and agents who need to know this information. In addition, we maintain physical, electronic, and procedural safeguards to protect your nonpublic, personal information.

As with any business policy, we must respond to changes in the law or in our business needs. Accordingly, we reserve the right to modify our Privacy Pledge as permitted or required by law.

Effective Date: March 2006.