Confidentiality & Privacy Policy Supplement
Confidentiality
It is the Firm’s policy that Client information must be kept confidential at all times by the Firm and its Staff. All client account and client-related information and data is governed by the Firm’s confidentiality obligation and duty as covered by the governing client investment management agreement or advisory services agreement.
Disclosure of information shall only be to support the delivery of services for the client account (e.g., disclosure of required details to unaffiliated third parties and other vendors; adequate information provided to support the activities of an independent contract consultant).
Preservation Of Confidential Information: Privacy
In the conduct of its business, the Firm collects nonpublic information about its clients that is provided by its clients, or obtained with its clients’ authorization. It is the Firm’s policy not to disclose such nonpublic information, except as required or permitted by law. Permitted disclosures will include, for example, the provision of information to employees and unaffiliated third parties who need to have such information in order to assist the Firm in providing services to its clients.
The Firm is aware of Regulation S-P governing the privacy of “consumer financial information” (the “Privacy Rule”). The Privacy Rule governs the treatment of nonpublic personal information about retail or individual clients who obtain financial products or services primarily for personal, family or household purposes. The Firm services solely institutional clients, and it is not anticipated that any of the Firm’s services will be provided to retail or individual clients. The Firm will comply with the Privacy Rule when as it may hereafter apply to a particular client relationship.
If there are any questions or issues relating to this Policy, Firm Staff should confer with the CCO and/or Firm Management.