PRIVACY POLICY
ALM First considers client information and data confidential. Our clients’ privacy is important to us.
While information and data are fundamental to our ability to provide advisory and ALM services, we fully recognize the importance of keeping the information secure. This information may include financial data, member data, and other documents provided by our clients. ALM First recognizes that certain information provided is non-public, confidential, and proprietary in nature.
- ALM First protects your information from unauthorized access, using established and exacting standards. Confidential and proprietary information will be kept confidential and shall not be disclosed by ALM First in any manner, in whole or in part, and shall not be used for any purposes other than providing agreed upon services.
- ALM First educates employees on the importance of maintaining the confidentiality of information.
- ALM First reveals confidential information only to those employees who need to know the information. Access is restricted to those employees who provide products and services for our clients. Background checks are conducted on all employees and agents with access to any information. Physical, electronic and procedural safeguards are maintained that comply with federal standards and leading industry practices to safeguard client nonpublic information.
- ALM First protects to the extent possible, any unauthorized intrusion including firewalls, client/employee identity authentication, and secured physical storage.
- ALM First Systems Administration authorizes users and establishes IDs and strong passwords such that only these authorized users can access ALM systems and applications. Antiviral and protection software are utilized and kept updated to ensure protection of emails, data and files utilized in the course of business.
- ALM First requires that computers on the network are logged off at the end of business each day and screen savers and locking devices are used by employees during business hours.
- ALM First uses digital IDs certified by Verisign, an industry leader in digital id certificates, to authenticate client information and provide access to a secure site for data transfer and the uploading and downloading of information in a protected environment. This system of digital ID authentication through Verisign allows the implantation of the Secure Sockets Layer (SSL) protocol, the standard technology for secure communications.
- Client information and records are kept in folders while in use and then are stored in a private file room only accessible by appropriate employees. Sensitive files are maintained in a fireproof safe.
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Code of Ethics
ALM First’s Code of Ethics sets the tone for the conduct and professionalism of our employees, officers, and directors. Because the ethical culture of our firm is of critical importance and ethical leadership begins at the highest levels, the Code of Ethics has the complete endorsement of senior management and covers all employees at ALM First.
Our Code of Ethics has been established to:
- Protect ALM First’s clients by deterring misconduct
- Educate employees regarding ALM First’s expectations and the regulations governing their conduct
- Remind employees they are in a position of trust and must act with propriety at all times
- Protect the reputation of ALM First
- Guard against violation of the securities laws
- Establish policies and procedures for employees that reinforce ethical behavior and allow ALM First to determine if employees are complying with ALM First’s ethical principles
GENERAL PRINCIPLES:
ALM First’s fiduciary duty is to its clients. Personal securities transactions must be conducted in compliance with the Code of Ethics and the policies and procedures controlling trading activities to avoid any actual or potential conflict of interest or abuse of an employee’s position of trust. ALM First is committed to providing services in a fair and professional manner and to fully disclose key elements of these services to clients. Independence in the investment decision making process is important and the interest of the client always comes first. Client information and holdings are confidential and maintained in an environment of confidentiality and trust. Additionally, employees are required to comply with all applicable federal securities laws and regulations. Failure to comply with ALM First’s Code of Ethics, standards of conduct, and policies and procedures may result in disciplinary action, including termination of employment. The Code of Ethics covers federal securities laws, conflicts of interest, insider trading, personal securities transactions, gifts and entertainment, confidentiality, service on boards and other outside activities, and marketing and promotional activities.
A copy of ALM First’s complete Code of Ethics and the ADV Statement can be obtained upon request. Please contact Sharon Criswell, Chief Compliance Officer at 214.451.2390 or scriswell@almfirst.com to request your copy.
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