Call Us! 855-ZENVIBA (936-8422)

We Invest in People and Ideas               Innovation Does Not Respect Tradition, and Neither Do We               We are Creatives, Environmental Capitalists, Social Entrepreneurs, Educators and Globalists               We Bring Meaning to Investing               Innovation Without Purpose is an Empty Exercise

Who We Are

Capitalists

Socialists

Educators

Disclosures

Your Privacy Is Important to Zenviba

In the course of serving you as an individual client or as someone associated with a corporate or institutional client, Zenviba may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term "Zenviba" refers to Zenviba Ventureprises and its affiliates worldwide.

The Sources of Information

The personal information we collect about you comes primarily from the forms and materials you submit to Zenviba during the course of your relationship with us. We may also collect information about your transactions and experiences with Zenviba relating to the products and services Zenviba provides.

Our Use of Your Personal Information

We may use your personal information to:

If your relationship with Zenviba ends, Zenviba will continue to treat your personal information, to the extent we retain it, as described in this policy.

Disclosures of Your Personal Information within Zenviba

In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within Zenviba may be given, or given access to, your personal information. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Zenviba is provided below, under Information Security: How We Protect Your Privacy.

Disclosures of Your Personal Information to Third Parties

Zenviba does not disclose your personal information to third parties, except as described in this policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Zenviba, including those that provide professional, legal or accounting advice to Zenviba. Non-affiliated companies that assist Zenviba in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that Zenviba dictates.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.

You should know that Zenviba will not sell your personal information.

Information Security: How We Protect Your Privacy

Zenviba is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Zenviba employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, our service providers are held to stringent standards of privacy. We also maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure Protecting information during transmission through various means including, where appropriate, encryption; and

Privacy and the Internet

The following additional information will be of interest to you as a visitor to this site:

Other Privacy Policies or Statements; Changes to Policy

This policy provides a general statement of the ways in which Zenviba protects your personal information. You may, however, in connection with specific products or services offered by Zenviba, be provided with privacy policies or statements that supplement this policy. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Web site. This version of the Policy is effective January 1, 2017.

TERMS OF USE

Access to the Zenviba Web site defined below is provided by Zenviba. For purposes of this agreement, "Zenviba" shall mean Zenviba Ventureprise and its affiliates, and their officers, directors, managing directors, partners, and employees. The "Zenviba Web site" shall mean the Web site of Zenviba Ventureprises available to the general public and located at zenviba.com and select other domains.

Monitoring by Zenviba

Your use of the products and services on this Web site may be monitored by Zenviba, and that the resultant information may be used by Zenviba for its internal business purposes in accordance with applicable laws.

Information Made Available Through this Service

You are permitted to store, display, analyze, modify, reformat, and print the information made available to you via these services only for your own use. You are not permitted to publish, transmit, or otherwise reproduce this information, in whole or in part, in any format to any third party without the express written consent of Zenviba. In addition, you are not permitted to alter, obscure, or remove any copyright, trademark or any other notices that are provided to you in connection with the information. Zenviba reserves the right, at any time and from time to time, in the interests of its own editorial discretion and business judgment to add, modify, or remove any of the information. These Terms and Conditions of Use are not intended to, and will not, transfer or grant any rights in or to the information other than those which are specifically described herein, and all rights not expressly granted herein are reserved by Zenviba or the third-party providers from whom Zenviba has obtained the information. You are required to read and abide by any additional terms and conditions that may be posted on this service from time to time concerning information obtained from specific third party providers. Such third-party providers shall have no liability to you for monetary damages on account of the information provided to you via this service.

No warranties made as to content; no responsibilities to update: Zenviba makes no warranty, express or implied, concerning this service. The services provided by us and our third-party providers are on an "AS IS" basis at your sole risk. Zenviba expressly disclaims any implied warranty of merchantability or fitness for a particular purpose, including any warranty for the use or the results of the use of the services with respect to their correctness, quality, accuracy, completeness, reliability, performance, timeliness, or continued availability.

Neither Zenviba nor any of its third-party providers shall have any responsibility to maintain the data and services made available on this Web site or to supply any corrections, updates, or releases in connection therewith. Availability of data and services are subject to change without notice.

No liability for content; no liability arising from use

Zenviba shall have no liability, contingent or otherwise, to you or to third parties, or any responsibility whatsoever, for the failure of any connection or communication service to provide or maintain your access to this service, or for any interruption or disruption of such access or any erroneous communication between Zenviba and you, regardless of whether the connection or communication service is provided by Zenviba or a third party service provider. Zenviba shall have no liability, contingent or otherwise, to you or to third parties, for the correctness, quality, accuracy, timeliness, reliability, performance, continued availability, completeness or delays, omissions, or interruptions in the delivery of the data and services available on this Web site or for any other aspect of the performance of this service or for any failure or delay in the execution of any transactions through this service. In no event, will Zenviba be liable for any special, indirect, incidental, or consequential damages which may be incurred or experienced on account of you using the data or services made available on this Web site, even if Zenviba has been advised of the possibility of such damages. Zenviba will have no responsibility to inform you of any difficulties experienced by Zenviba or third parties with respect to the use of the services or to take any action in connection therewith.

No warranties made as to security

Zenviba makes no warranty whatsoever to you, express or implied, regarding the security of the site, including with respect to the ability of unauthorized persons to intercept or access information transmitted by you through this service.

No representations made as to other sites or links

This service may provide links to certain Internet sites (the "Sites") sponsored and maintained by third parties. Zenviba is providing such links solely as a convenience to you. Accordingly, Zenviba makes no representations concerning the content of the Sites. The fact that Zenviba has provided a link to the Site does not constitute an endorsement, authorization, sponsorship, or affiliation by Zenviba with respect to the Site, its owners, or its providers. Zenviba has not tested any information, software, or products found on any of the Sites and therefore does not make any representations with respect thereto, including any representations regarding the content or sponsors of the Site, or the suitability or appropriateness of the products or transactions described therein.

ANTI-MONEY LAUNDERING POLICY

Purpose & Objective

This policy outlines the principles that Zenviba Ventureprises and its affiliates (collectively "Zenviba" or "we") follow to achieve zero-tolerance against money laundering. The objective of our anti-money laundering policy (AML) is to ensure that appropriate AML procedures are in place across the globe to avoid any violations of relevant laws and regulations, including, among others, the Banking Secrecy Act (BSA), Financial Industry Regulatory Authority (FINRA) Rule 3310 and the Know Your Customer (KYC) Rule, as well as Counter Terrorism Financing (CTF).

Scope

This policy applies to all officers, directors, shareholders, employees and appointed third party representatives of Zenviba (including but not limited to agents, intermediaries, consultants and introducers) in all locations. Violation of this policy will be severely sanctioned, including where appropriate disciplinary procedures, up to and including termination of employment and possible referral to the appropriate criminal and/or regulatory authorities.

Zenviba intends to review doing business with others who do not commit to the same standard of zero-tolerance of money laundering, including joint ventures partners and distributors.

ANTI-CORRUPTION POLICY

Purpose & Objective

This policy outlines the principles that Zenviba Ventureprises and its affiliates (collectively "Zenviba" or "we") follow to achieve zero-tolerance against bribery and corruption. The objective of our anti-corruption policy is to ensure that appropriate anti-corruption and bribery procedures are in place across the globe to avoid any violations of relevant laws and regulations, including, among others, the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act 2010.

Scope

This policy applies to all officers, directors, shareholders, employees and appointed third party representatives of Zenviba (including but not limited to agents, intermediaries, consultants and introducers) in all locations. Violation of this policy will be severely sanctioned, including where appropriate disciplinary procedures, up to and including termination of employment and possible referral to the appropriate criminal and/or regulatory authorities.

Zenviba intends to review doing business with others who do not commit to the same standard of zero-tolerance of corruption, including joint ventures partners and distributors.

Policy Requirements

Zenviba has embedded within its business the following principles and controls to achieve zero tolerance against bribery and corruption:

No Acceptance or Offering of Bribes and Facilitating Payments

Strictly prohibited from giving or receiving bribes (i.e. personal benefit for any improper advantage) as well as facilitating payments (regardless of whether these are common practices in a particular country) which involve anything of value to government officials in order to expedite or facilitate routine, non-discretionary government actions.

Charitable and Political Donations

Prohibited from payment of donations that are linked to obtaining any improper advantage, including facilitating payments.

Gifts and Entertainment

Prohibited from providing gift or entertainment to clients, prospects, government officials or their family members when such expenses are not incurred while conducting company business and/or do not satisfy this policy and our related policies.

Payments and Recordkeeping

All relevant expenditures must be properly documented, approved and maintained for a minimum of 6 years.

Government Officials

Required to adhere to our additional recordkeeping requirements regarding all expenditures related to government officials. Written prior approval is required when a certain threshold is exceeded.

Due Diligence on Third Party Representatives

Required to conduct an appropriate due diligence review on background, reputation, and business capability before engaging or contracting with any third-party representatives and to include anti-corruption provisions in any such contract.

Periodic Training

Required to carry out appropriate training to employees regarding the Anti-Corruption Policy and their role to ensure compliance.

Monitoring & Reporting

We shall monitor compliance with our Anti-Corruption Policy. Further, all persons covered by this policy must promptly report any violation or suspected violation of this policy to the General Counsel or the Director of Compliance.

REGULATORY DISCLOSURES

Not an Offer for Sale, Solicitation or Recommendation

The material on this website has been prepared for informational purposes only without regard to any particular user's investment objectives, financial situation, or means, and Zenviba is not soliciting any action based upon it. This material is not to be construed as a recommendation; or an offer to buy or sell; or the solicitation of an offer to buy or sell any security, financial product, or instrument; or to participate in any particular trading strategy in any jurisdiction in which such an offer or solicitation, or trading strategy would be illegal. Certain transactions give rise to substantial risk and are not suitable for all investors. Although this material is based upon information that Zenviba considers reliable and endeavors to keep current, Zenviba has not verified this information and does not represent that this material is accurate, current, or complete and it should not be relied upon as such.

No Determination of Suitability Has Been Made

The fact that Zenviba has made the data and services provided on this website available to you constitutes neither a recommendation that you enter into a particular transaction nor a representation that any product described on this Web site is suitable or appropriate for you. Many of the products described on this website involve significant risks, and you should not enter into any transactions unless you have fully understood all such risks and has independently determined that such transactions are appropriate for you. Any discussion of the risks contained herein with respect to any product should not be considered to be a disclosure of all risks or complete discussion of the risks which are mentioned. You should neither construe any of the material contained herein as business, financial, investment, hedging, trading, legal, regulatory, tax, or accounting advice nor make this service the primary basis for any investment decisions made by or on behalf of you, your accountants, or your managed or fiduciary accounts, and you may want to consult your business advisor, attorney, and tax and accounting advisors concerning any contemplated transactions.

Investment Risk

All investment opportunities mentioned on this website are not insured, not guaranteed, and may lose value, including the principal amount invested. No assurances can be given that the Fund will achieve its investment objective. Past performance is no guarantee of future results.

Accredited Investor

If you are an Institutional Investor or an Accredited Investor and would like more information regarding investment opportunities on this website, including a Private Placement Memorandum, please contact Zenviba. Please read the prospectus carefully and consult with your financial advisor before investing.

An investor who meets certain net worth and income tests as detailed by the SEC's Regulation D, Section 501. Accredited investors are eligible to purchase private placement offerings under Regulation D, Rule 505 and Rule 506. These offerings are exempt from the registration and reporting requirement the SEC imposes on public companies.

Here is a brief version of the legal definitions. The term "natural person" is used to refer to a real person, since legally a "person" may be a corporation. Natural persons who individually or jointly with their spouse have a net worth in excess of $ 1 million.

Natural persons who have an income in excess of $200,000 for the two most recent years with an expectation of such income in the current year, or those natural persons who have joint income with their spouse for such periods in excess of $300,000.

Certain banks, insurance companies, investment companies, small business investment companies, certain employee benefit plans, savings & loan associations, building & loan associations, cooperative bank, homestead association, or similar institution supervised and examined by state or federal authority, with respect to purchases for their own account and in fiduciary capacity. Also, a broker/dealer registered the Commission under the Exchange Act purchasing for its own account as an investment is included.

THESE SECURITIES HAVE NOT BEEN REGISTERED UNDER THE SECURITIES ACT OF 1933 (THE "SECURITIES ACT") OR THE SECURITIES LAWS OF CERTAIN STATES AND ARE BEING OFFERED AND SOLD IN RELIANCE UPON AN EXEMPTION FROM THE REGISTRATION REQUIREMENTS OF THE SECURITIES ACT AND SUCH LAWS. THE SECURITIES HAVE NOT BEEN APPROVED OR DISAPPROVED- BY THE SECURITIES AND EXCHANGE COMMISSION (THE "SEC") OR BY ANY STATE SECURITIES COMMISSION OR OTHER REGULATORY AUTHORITY, NOR HAVE ANY SUCH AUTHORITIES PASSED UPON OR ENDORSED THE MERITS OF THESE SECURITIES OR THE ACCURACY OR ADEQUACY OF THIS CONFIDENTIAL PRIVATE PLACEMENT MEMORANDUM. ANY REPRESENTATION TO THE CONTRARY IS UNLAWFUL. INVESTMENT IN THE UNITS IS SPECULATIVE AND INVOLVES A HIGH DEGREE OF RISK AND PROSPECTIVE INVESTORS SHOULD BE AWARE THAT THEY MIGHT SUSTAIN A LOSS OF THEIR ENTIRE INVESTMENT. INVESTORS WILL BE REQUIRED TO MAKE REPRESENTATIONS WITH RESPECT TO THEIR NET WORTH AND INCOME AND TO REPRESENT, AMONG OTHER THINGS THAT THEY ARE FAMILIAR WITH AND UNDERSTAND THE TERMS OF THIS OFFERING. SEE "RISK FACTORS." THE UNITS ARE BEING OFFERED AND SOLD PURSUANT TO AN EXEMPTION PROVIDED BY RULE 506 OF REGULATION D OF THE SECURITIES ACT AND EXEMPTIONS UNDER CERTAIN STATE SECURITIES LAWS, OR CERTAIN RULES AND REGULATIONS PROMULGATED PURSUANT THERETO. THE UNITS MAY NOT BE TRANSFERRED IN THE ABSENCE OF AN EFFECTIVE REGISTRATION STATEMENT UNDER THE SECURITIES ACT AND APPLICABLE STATE SECURITIES LAWS OR AN OPINION OF COUNSEL ACCEPTABLE TO THE COMPANY THAT SUCH REGISTRATION IS NOT REQUIRED.

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