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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.

Please contact Deirdre Dillon, AML Compliance Officer, at One Maynard Drive, Suite 3200, Park Ridge, NJ, USA 07656 or at +1 201 391 0300 for further information, questions and/or concerns regarding Seix's AML Compliance Program.

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.

Terms of Use

The following terms of use (“terms”) govern your use of this website. Your use of this website and its content constitutes your acceptance of these terms. If you do not agree with these terms, you should immediately cease use of this website and its content.

Use of Information and Materials

Any person is hereby authorized to view the information available from this web site (“Information”) for informational purposes only. No part of this information may be redistributed, copied, or reproduced without the prior written consent of Seix Investment Advisors LLC ("Seix"). The product and fee information presented in this web site represent Seix offerings as of the most recent update. Rules, Regulations, Fee Schedules, and Service Agreements currently in effect take precedence over any information herein. The past performance of a mutual fund, security, or investment strategy cannot guarantee its future performance.

Copyright

All Information available through "www.seixadvisors.com" is the property of Seix or its information providers and is protected by intellectual property laws. All rights reserved.

You may not reproduce, retransmit, disseminate, sell, publish, or broadcast, the Information, nor shall the Information be used in connection with creating, promoting, trading, marketing investment products, without the express written consent of Seix or its information providers. You are entitled to use the Information for your private, non-commercial use only.

Trademarks/Service Marks

RidgeWorth Investments, RidgeWorth Capital Management, RidgeWorth Funds, and the Seix Investment Advisor LLC logo are registered service marks of RidgeWorth Capital Management LLC. All other names, logos, products and proprietary tools are the intellectual property of RidgeWorth Capital Management LLC or Seix, except those clearly identifying or identified with other persons, which are the property of their respective owners.

Changes

Seix reserves the right to change these terms and this website at any time, without any prior notice, and at its sole discretion. As such modifications may result in the superseding of certain terms, you should review these terms on a periodic basis for changes. Your continued use of this website constitutes your acceptance of all terms, including those that have been changed.

No Warranties

The information and materials contained in the web site are provided "as is" without warranty of any kind, either express or implied, including without limitation, any warranty of accuracy, adequacy, completeness, or timeliness of the information and materials, title, non-infringement of third party rights, merchantability, fitness for a particular purpose and freedom from computer virus.

Third Party Links

Seix is happy to make available to you links to other sites on the World Wide Web. Seix believes the links contained on its pages are to reputable companies. Nevertheless, Seix makes no representations or warranties regarding non-Seix sites or the companies maintaining them. Seix does not control or monitor such web sites and Seix does not endorse the content or the use of such web sites. If you choose to access non-Seix web sites through links on our pages, you accept responsibility for all related risks.

Limitation of Liability

In no event will Seix or any of its affiliates be liable for any damages, losses or expenses, including without limitation, direct or indirect, special, incidental or consequential damages, arising out of or in connection with this web site, use thereof or reliance on any information contained herein, even if Seix or any of its affiliates are notified of the possibility of such damages.

Choice of Law; Unenforceability

Your access to and use of this web site, and these terms, are governed by and will be construed in accordance with the laws of the State of Georgia, without regard to principles of conflicts of laws. In the event that any provision of these terms is held unenforceable, the validity or enforceability of the remaining provisions will not be affected, and the unenforceable provision will be replaced with an enforceable provision that comes closest to the intention underlying the unenforceable provision.

Form ADV

Seix Form ADV Part 1 (1 MB, PDF)

Seix Form ADV Part 2a (272 KB, PDF)