COMMITMENT TO SHAREHOLDER PRIVACY
OHA Investment Corporation (the "Company") is committed to handling information regarding our shareholders responsibly and in accordance with applicable laws, rules and regulations. Technology has dramatically changed the way information of all kinds is gathered, used and stored, but the importance of preserving the security and confidentiality of shareholder information has remained a core value of the Company.
We recognize and respect the privacy expectations of each of our shareholders. Confidentiality and protection of shareholder information is one of our fundamental responsibilities.
COLLECTION AND DISCLOSURE OF SHAREHOLDER INFORMATION
The only information we collect from shareholders is the name and address of the shareholder and the number of shares held by the shareholder.
This information is used only so that we can service shareholder accounts, send shareholders annual reports and other information about the Company, and send shareholders proxy statements or other information required by law.
We may disclose shareholder information to certain third parties:
a. As authorized - if the shareholder requests or authorizes the disclosure of the information;
b. As permitted by law - for example, sharing information with companies who maintain or service shareholder accounts for the Company is permitted and is essential for the Company to provide shareholders with necessary or useful services with respect to their investment, such as record keeping, processing trades and mailing information to shareholders. These companies are required to protect shareholder information and use it solely for the purpose for which they received it;
c. To authorized employees of Oak Hill Advisors, L.P., or its affiliates (collectively, the "Adviser")- It is our policy that only authorized employees of the Adviser who need to know shareholder information will have access to it; and/or
d. As required by law - for example, as part of a regulatory or similar filing with certain regulatory and/or governmental agencies.
SECURITY OF SHAREHOLDER INFORMATION
We do not disclose, and do not reserve the right to disclose, any nonpublic personal information about our shareholders to any affiliates or nonaffiliated third parties, except disclosures in the ordinary course of business, such as to process transactions, maintain accounts, respond to court orders and legal investigations.
We restrict access to nonpublic personal information about shareholders solely (i) to those service providers who need to know that information to provide products or services to shareholders, (ii) to authorized employees of the Adviser who need to know shareholder information, or (iii) as otherwise required by law. We maintain physical, electronic, and procedural safeguards that comply with federal and state regulations to guard a shareholder's nonpublic personal information.
We adhere to the policies and practices described in this Policy regardless of whether the shareholder is a current or former shareholder.
This Policy is current as of the date hereof, but as circumstances or requirements change, we may need to amend this Policy. We will notify our shareholders of any material amendment.