Security Policy

YOUR PRIVACY IS IMPORTANT TO FINANCIAL POLICY COUNCIL INC

In the course of serving you as an individual client or as someone associated with a corporate or institutional client, Financial Policy Council Inc 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 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 “Financial Policy Council Inc” refers to Financial Policy Council Inc Inc., and its affiliates worldwide.

The personal information we collect about you comes primarily from the materials you submit to Financial Policy Council Inc during the course of your relationship with us. We may also collect information about your transactions and experiences with Financial Policy Council Inc relating to the products and services Financial Policy Council Inc provides. In addition, depending on the products or services you require, Financial Policy Council Inc may obtain additional information about you, such as your credit history, from consumer reporting agencies.

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from other means. In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.

WE MAY USE YOUR PERSONAL INFORMATION TO:

Administer, operate, facilitate and manage your relationship with Financial Policy Council Inc. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively; Contact you or, if applicable, your designated relationship manager(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship; Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

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

YOUR PRIVACY IS IMPORTANT TO FINANCIAL POLICY COUNCIL INC

Financial Policy Council Inc 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 or facilitate your transactions with Financial Policy Council Inc, including those that provide professional, legal or accounting advice to Financial Policy Council Inc. Non-affiliated companies that assist Financial Policy Council Inc 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 Financial Policy Council Inc 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 Financial Policy Council Inc will not sell your personal information under any circumstances.

This policy provides a general statement of the ways in which Financial Policy Council Inc protects your personal information. You may, however, in connection with specific products or services offered by Financial Policy Council Inc, 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 4, 2010.

BEWARE FRAUDULENT E-MAILS AND WEB SITES

“Phishing” is a rampant Internet scam that relies on “spoofed” e-mails, purportedly from well known firms, to lure individuals to fraudulent Web sites that look and feel like the well known firm’s Web site. At such Web sites, victims are asked to provide personal information about themselves, such as their name, address and credit card number. These fraudulent e-mails and Web sites may also try to install malicious software on your computer that monitors your activities and sends sensitive personal information (your passwords, for example) to a remote location. With that information, criminals can commit identity theft, credit card fraud and other crimes.

You can protect yourself by following these best practices when using the Internet:

Be aware that e-mail is insecure and easy to forge. E-mail that appears to be from a friend or company you do business with may be fraudulent and designed to trick you into providing personal information about yourself or installing dangerous software. Do not respond to e-mails or pop-up messages that solicit your personal information: name, address, Social Security number, etc. Only access trusted Web sites that you found other than by clicking on a Web site address in an e-mail and then added to your browser’s bookmarks. Otherwise, manually type the address into your browser and then bookmark it. When you receive an e-mail, rather than clicking on a Web site address in the e-mail, which can bring you to a fraudulent site, use the bookmark to access that site.

If you receive an e-mail from Financial Policy Council Inc you are uncertain about, or which you believe to be fraudulent, please forward it to investigation@financialpolicycouncil.org

Financial Policy Council Inc will investigate the e-mail and respond back to you.

No security practice is foolproof. You can, however, help protect yourself by following these best practices to secure your personal computer:

Install antivirus and anti-spyware software on your computer and make sure it is up to date with the most recent virus/spyware signatures. Make sure your computer is up to date with the most recent software patches. Patches are software updates that often address software vulnerabilities that phishing scams and viruses exploit. Install a firewall between your computer and the Internet. A firewall is software or hardware that acts as a buffer between your computer and the Internet that limits access to your computer and blocks communications from unauthorized sources.

Please contact the manufacturer of your computer for additional information and recommendations.

PHISHING: Phishing attacks use ”spoofed” e-mails and fraudulent Web sites designed to fool recipients into divulging personal financial data such as credit card numbers, account usernames and passwords, Social Security numbers, etc. By hijacking the trusted brands of well-known banks, online retailers and credit card companies, phishers are able to convince up to 5% of recipients to respond to them.

FIREWALL: A system designed to prevent unauthorized access to or from a private network. Firewalls can be implemented in both hardware and software, or a combination of both. Firewalls are frequently used to prevent unauthorized Internet users from accessing private networks connected to the Internet, especially intranets. All messages entering or leaving the intranet pass through the firewall, which examines each message and blocks those that do not meet the specified security criteria.

PATCH: Also called a service patch, a fix to a program bug. A patch is an actual piece of object code that is inserted into (patched into) an executable program. Patches typically are available as downloads over the Internet.

COMPUTER VIRUS: A program or piece of code that is loaded onto your computer without your knowledge and runs against your wishes. Viruses can also replicate themselves. All computer viruses are manmade. A simple virus that can make a copy of itself over and over again is relatively easy to produce. Even such a simple virus is dangerous because it will quickly use all available memory and bring the system to a halt. An even more dangerous type of virus is one capable of transmitting itself across networks and bypassing security systems.

ANTIVIRUS SOFTWARE: A utility that searches a hard disk for viruses and removes any that are found. Most antivirus programs include an auto-update feature that enables the program to download profiles of new viruses so that it can check for the new viruses as soon as they are discovered.

URL: Abbreviation of Uniform Resource Locator, the global address of documents and other resources on the World Wide Web.

SPOOF: To fool. In networking, the term is used to describe a variety of ways in which hardware and software can be fooled. IP spoofing, for example, involves trickery that makes a message appear as if it came from an authorized IP address (the numerical identifier for a computer).