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Legal/Privacy Policy

  1. Legal & Compliance
  2. Anti-Money Laundering Policy
  3. Proxy Voting Policies
  4. Seix Privacy Practices
  5. Terms of Use
  6. Form ADV

Anti-Money Laundering Policy

In 2001, President Bush signed into law Public Law No. 107-56, Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act). This law significantly impacts the financial services industry and providers of electronic communications services and grants law enforcement expanded investigative authority over Client information that may in certain circumstances supercede Gramm-Leach-Bliley Act and Regulation S-P restrictions.

Seix has, as a best practice, adopted an Anti-Money Laundering (AML) Compliance Program with which all Seix officers and employees are required to comply. Accordingly, Seix may, at any time, be required to obtain Client verification and certification of residency. This may include, but is not limited to, obtaining proof of tax identification, individual social security numbers, state or country of residency and birth, passport identification, bank account verifications, and other documentation as required by the federal government and/or other regulatory agencies. Seix is restricted from opening and/or maintaining accounts with/through/for shell banks and will immediately cease managing such accounts regardless of when the situation is discovered.

Proxy Voting Policies

Proxy Policy (28 KB, PDF)

Seix Privacy Practices

Seix its directors, officers and employees are strongly committed to protecting the online privacy of all clients and/or visitors. In accordance with the Privacy Act of 1974, the Gramm-Leach-Bliley Act and the subsequent Securities and Exchange Commission's Privacy of Consumer Financial Information Regulations (Regulation S-P) and Regulation S-AM requirements, this website uses standard encryption and password-protected protocols.

In the ordinary course of doing business, and in order to provide customized services and products, it may be necessary for Seix to procure certain personal information from clients and/or visitors to this website. In addition, Seix may also periodically request other personal data in order to initiate and maintain accounts and relationships and to provide for supplemental products or services specifically tailored to meet its clients' and/or visitors' ongoing needs.

Seix is committed to ensuring the security of all personal information and as an integral part of its compliance program, Seix has designed its privacy control policies and procedures to prevent (to the extent possible) unauthorized disclosure and/or use of all such information. Seix does not generally make use of cookies or other web originated electronic forms of information tracking to procure personal information but it reserves the right to do so.

Seix will, to the best of its abilities, limit the sharing of any accumulated personal data to select business affiliates, partners, vendors and other parties authorized to act on its behalf and on behalf of its clients and/or visitors. All such groups and individuals will, of course, be bound by similar confidentiality agreements prior to Seix releasing any information. In addition, there are currently several states that require clients and visitors to provide "opt-in" permission for Seix to share any information. To the extent that Seix is made fully aware of the residency of such individuals, it will do its utmost to share any personal information with no other parties without consent. Currently, several states require firms to provide "opt-in" releases. Individuals should, therefore, provide Seix with a state of residence along with any initial contact information. Seix may not be held responsible in instances where the individual does not provide sufficient state of residency information. Everyone must realize however, that restricting Seix's ability to share information with certain parties may negatively impact its ability to perform its duties on behalf of those clients.

Occasions may arise wherein the Seix website may include links to unaffiliated third party websites. These transfers are provided solely as a convenience to clients and/or visitors and should not be construed as part of the Seix organization and Seix cannot guarantee or be held responsible for any personal information transported by the client through any such links. Although Seix makes every attempt to limit linking to reputable sites, Seix does not review or control other sites and makes no representation that those sites are competent, experienced or compliant with current industry and government regulations.

Seix reserves the right to change this statement at any time by posting revisions on the official Seix website. Although Seix will make every attempt to prevent the unauthorized use of client and/or visitor information, it can make no guarantees. This privacy policy is not intended to, and does not create any contractual or other legal rights in or on behalf of any party.

For further information regarding Seix's Privacy Policies and Procedures and depending on the state of residency, to either "opt-in" or "opt-out," please contact Deirdre Dillon, Chief Compliance Officer of Seix Investment Advisors LLC, at One Maynard Drive, Suite 3200, Park Ridge, NJ, USA 07656 or at +1 201 391 0300.

Seix Privacy Policy

In accordance with the Gramm-Leach-Bliley Act (GLB) and subsequent Securities & Exchange Commission (SEC) Regulation S-P and Regulation S-AM requirements, Adviser has enacted certain policies and procedures regarding the protection of client information.  Adviser’s general policy is set forth herein.

Privacy Act Policies and Procedures

Adviser, its directors, officers, and staff are committed to protecting the confidentiality of all client information.  In accordance with government regulations, Adviser will, to the best of its abilities, limit the sharing of any accumulated nonpublic personal data to select business partners, organizations, government officials, vendors or third parties who are authorized to act on its behalf and/or on behalf of its clients.

Due to the various products and services offered by Adviser, any or all of the individual products and services or a combination of products and services may be offered to existing clients or prospective clients at any time.  Thus, in order to provide multiple products and services, it will be necessary, in the ordinary course of doing business (including but not limited to processing transactions and maintaining or transferring accounts), for Adviser officers and staff members to share certain personal data with other employees, third party vendors and/or other industry or product related firms.  Such information will be designated as restricted and provided to outside vendors, firms, or individuals only when/as authorized by Adviser supervisors or managers, and only on a need-to-know basis. In addition, Adviser will apply the same restricted access to information provided by former clients and former prospective clients.  Adviser has also established compliance guidelines which restrict general access to specified client information, yet permit the firm to pursue the best overall product and service options for its clients and prospective clients.

Adviser has policies and procedures in place designed to dispose of client and prospective client information in a confidential manner when/as appropriate. In addition to the above mentioned confidentiality measures, Adviser must honor all properly submitted regulatory and/or other appropriate governmental requests.  Adviser generally seeks to keep confidential holdings and transaction information, but may provide information on client holdings or transactions for legitimate business purposes (for example, to a client’s consultant, to rating agencies, for limited marketing purposes, etc.) and generally subject to obtaining a confidentiality agreement from the recipient.

Client Privacy Preferences

Clients and/or prospective clients may choose, at any time, to inform Adviser to limit its sharing of certain personal information with affiliated or non-affiliated firms or vendors by contacting Adviser and "opting out" at +1 201 391 0300 or via mail directed to the Chief Compliance Officer, One Maynard Drive, Suite 3200, Park Ridge, NJ, USA 07656.  Individuals who reside in California and Massachusetts must notify Adviser to “opt in”.  That is, individuals of those states must specifically grant Adviser permission to share any information outside of Adviser.  Clients and prospective clients must understand that “opting out” or failing to “opt in” may severely restrict or limit Adviser’s ability to carry on business on behalf of those clients and in certain circumstances could affect the client’s account and/or investment returns.  

Adviser reserves the right to change nonmaterial information in this statement at any time without any specific public notification.  All material changes to this statement will be posted to the official Adviser Internet Site www.seixadvisors.com, with all disclosure documents amended and all clients notified as soon as is reasonably possible.

Although Adviser will make every attempt to prevent the unauthorized use of client or prospective client data, there can be no guarantees.  This privacy policy is not intended to, and does not, create any contractual or other legal rights in or on behalf of any party.  Please contact Adviser at the sources listed above with questions and/or concerns.

Information We Collect

"Nonpublic personal information" is personally identifiable financial information about you as an individual or your family. The type of nonpublic personal information we have about you may include the information you provide on your account application; information you provide in telephone calls or correspondence with us; information about your transactions and holdings in Seix, and information about how you vote your shares.

Information We Disclose

Seix’s policy is to only disclose nonpublic personal information about you to companies that provide necessary services such as Seix’s transfer agent, distributor, administrator or investment adviser; affiliates of Seix, or as may otherwise be permitted or required by law or authorized by you.

How We Safeguard Your Information

We restrict access to nonpublic personal information about you to those persons who are required to have certain information in order to provide services to you, or who are permitted by law to receive it. We have strict internal policies against unauthorized disclosure or use of customer information. We maintain customer information as mandated by financial regulations, and policies and procedures are in place for appropriate confidential destruction of all restricted access data.

If you have any questions regarding Seix’s Privacy Policy, please contact Deirdre Dillon, Chief Compliance Officer of Seix Investment Advisors LLC, at One Maynard Drive, Suite 3200, Park Ridge, NJ, USA 07656 or at +1 201 391 0300.

Legal Statement: Terms and Conditions of Use

By using this site, you agree to the following terms:

Information on this Web Site

The information contained on this site does not constitute an offer or solicitation for the sale of any security or any other product or service from Seix Investment Advisors or its affiliated entities. Content is provided for informational purposes and should not be construed as a substitute for legal or financial advice from a professional advisor.

Restrictions on Use

Your use of the materials on this site, including content, documents, products, software, graphics and text, and all software, design, programming techniques and documentation used to operate and support the site, is subject to these terms. You may download material displayed on this site to your computer and you may print, email, or distribute copies of the information contained on this site, provided you do not remove any copyright, trademark, or other proprietary notices contained on the materials. Except as authorized in writing by Seix Investment Advisors or its affiliated company Virtus Investment Partners, no materials from this site or any Web site owned, operated, licensed, or controlled by Seix Investment Advisors or Virtus Investment Partners may be reproduced, republished, posted, or hyperlinked.

Where We Are Authorized to Conduct Business

The services and products described and information provided through this site are directed to and are intended to be made available only to persons in the United States and are not intended for distribution to, or use by, any person in any other country or any jurisdiction where such distribution or use would be contrary to law or regulation or that would subject the funds supported by Seix Investment Advisors, or any of its affiliates, to any registration requirement within such jurisdiction or country. Persons who access this site do so on their own initiative, and are responsible for compliance with applicable local laws or regulations.

Our Privacy Policy

Seix Investment Advisors is firmly committed to maintaining the privacy of all visitors to our site. For more information, see our Privacy Policy.

Modification of this Site and Materials

Seix Investment Advisors may, at any time and for any reason, stop making this site available and/or remove and discard any materials within it. Further, Seix Investment Advisors or its affiliates shall not be liable to you or any third party for any modification, suspension or discontinuance of the site.

Links

This site may provide, or third parties may provide, links to other Web sites or resources. Seix Investment Advisors and Virtus Investment Partners have no control over such sites and resources, are not responsible for their availability, and do not endorse and are not responsible or liable for any content, advertising, products, or other materials on or available from them. Seix Investment Advisors or Virtus Investment Partners shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of such sites or resources. Your use of such sites or resources shall be subject to the terms and conditions set forth by them.

Proprietary Rights Retained by Seix Investment Advisors

All rights, title and interests in and to the site and its materials, including, but not limited to, all patent rights, copyrights, trade secrets, trademarks, site marks, and other inherent proprietary rights, are retained by Seix Investment Advisors or its licensors. Except as expressly authorized by Seix Investment Advisors or its affiliates herein, you agree not to make, copy, display, modify, rent, lease, license, loan, sell, distribute, or create derivative works of the site or its materials in whole or in part. Any modification of the site or its materials for any purpose is in violation of these terms.

Trademark Information

The names Seix Investment Advisors LLC and Virtus Investment Partners, Inc. and logo marks are  trademarks and service marks of the respective firm and may not be displayed or otherwise used in any manner without the prior written consent of the respective firm. All other trademarks not owned by Virtus that appear on this site are the property of their respective owners.

Disclaimer of Warranties

This site and its materials are provided "as is" and "as available" and without warranties of any kind, either express or implied, including, but not limited to, implied warranties of accuracy, completeness, non-infringement, merchantability and fitness for a particular purpose, including, without limitation, whether any  product  described on the site is appropriate to meet your needs.

Without limitation of the foregoing, Seix Investment Advisors and Virtus Investment Partners make no warranty that (i) the site will meet your requirements; (ii) the site will be uninterrupted, timely, secure, or error-free; (iii) the results that may be obtained from use of the site will be accurate or reliable; (iv) the quality of any products, sites, information, or other material obtained by you through the site will meet your expectations; or (v) any errors in the site will be corrected.

Any material viewed, downloaded or otherwise obtained through the use of the site is done solely at your own discretion and risk, and you will be solely responsible for any damage to your computer system or loss of data that results from the viewing or download of any such material.

No information provided to you through this site shall be the basis for any warranty between you and Seix Investment Advisors or Virtus Investment Partners.

Limitations of Liability

Seix Investment Advisors and its officers, directors, employees, consultants, and contractors shall not be liable for any damages, losses, costs or injuries suffered as a result of or in relation to this site or its materials, your use of either of the foregoing, or your breach of these terms or restrictions. In no event shall Seix Investment Advisors be liable for any indirect, punitive, special, incidental, or consequential damages (including, without limitation, loss of sales, business, revenue, profit, use, data, or other economic advantage), however it arises, whether for breach of contract or in tort, even if you have been advised of the possibility of such damages. In no event shall Seix Investment Advisors or its affiliates be liable to you for damages in an amount greater than $50 in the aggregate.

Indemnification

You shall indemnify, defend and hold Seix Investment Advisors and Virtus Investment Partners harmless from and against all claims, actions, liabilities, damages, losses, debts, costs and expenses, including, without limitation, reasonable attorneys' fees, arising out of or relating to (i) your use or modification of this site or its materials; (ii) any information content or materials submitted or provided by you; or (iii) your breach of any of these terms or restrictions.

Submissions

To avoid any misunderstandings as to ownership or compensation, this site should not be used to submit ideas, suggestions or materials (collectively, submissions) to Seix Investment Advisors or Virtus Investment Partners. Employees, consultants and other representatives of Virtus have many creative ideas of their own, some of which may be similar to your submissions. In addition, while you may believe that your submissions are novel or unique, it is possible that they are otherwise known by Virtus or within the financial or other industries. If, despite our request, you submit any submissions to either firm via this site, such submissions shall become our property and you hereby assign to Seix Investment Advisors or Virtus Investment Partners, without further consideration, all of your rights, title and interests in and to the same, including, without limitation, any pertinent copyright, trade secret, patent and any other intellectual property rights. Any additional or different terms of ownership or use submitted by you in connection with any such submission shall be void. In addition, neither Seix Investment Advisors nor Virtus Investment Partners shall be under any obligation of confidentiality with respect to any such submission and shall not be liable for any use or disclosure of the same.

Copyright and Copyright Agents

Seix Investment Advisors and Virtus Investment Partners respect the intellectual property of others, and we ask our users to do the same. If you believe that your work has been copied in a way that constitutes copyright infringement, please provide our Copyright Agent the following information:

  • An electronic or physical signature of the person authorized to act on behalf of the owner of the copyright interest;
  • A description of the copyrighted work that you claim has been infringed;
  • A description of where the material that you claim is infringing is located on the site;
  • Your address, telephone number and email address;
  • A statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent or the law;
  • A statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner's behalf.

The Copyright Agent for notice of claims of copyright infringement on its site is:

Compliance Officer
Virtus Investment Partners
100 Pearl Street
Hartford, CT 06103

 

General Information

You also may be subject to additional terms and conditions that may apply when you use subsidiaries' sites, third-party content or third-party software. These terms and the relationship between you and Seix Investment Advisors shall be governed by the laws of the State of Connecticut  and controlling United States federal law without regard to conflict of law provisions. The failure of Virtus to exercise or enforce any right or provision of these terms shall not constitute a waiver of such right or provision. If any provision of these terms is found by a court of competent jurisdiction to be invalid, the parties nevertheless agree that the court should endeavor to give effect to the parties' intentions as reflected in the provision, and that the other provisions of these terms shall remain in full force and effect. The section titles included in this statement are for convenience only and have no legal or contractual effect.

Changes to Terms

Seix Investment Advisors reserves the right, in its sole discretion at any time, to change, modify, add to or delete portions of these terms and/or the Privacy Policy. You are bound by any such revisions and should periodically visit this page to review the most recent terms. Your continuing use of this site following the posting of any such changes, modifications, additions or deletions shall constitute your acceptance of and assent to the same. If you decide to purchase securities or other products or services that are referred to on the site, the terms and conditions specified in the agreement with Seix Investment Advisors will apply.

Form ADV

Seix Form ADV Part 1 (1 MB, PDF)

Seix Form ADV Part 2a (283 KB, PDF)