Brandywine Asset Management, Inc. Privacy of Client Information

Last Updated 1/14/2010

Employees of Brandywine Asset Management, Inc. are forbidden from disclosing nonpublic personal information ("NPI") about any of our clients, except as required by law, unless directed to do so by that client. All paper format client-related NPI is maintained in locked file cabinets in order to restrict access by unauthorized individuals, until it is disposed of by shredding. Any electronic client-related NPI is protected by a Microsoft ISA software firewall against outside intruders and by password protection on in-house computer stations. Computer Associates eTrust software protects servers and client workstations from viruses. Scheduled updates and scans ensure up-to-date virus definition files. Scheduled backups are used to save all critical data to disk and tapes.

Pursuant to Regulation S-P issued by the Securities and Exchange Commission and adopted by the NFA, the Firm has instituted a Privacy Policy (see Exhibit I attached) to protect NPI about our clients under Section 504 of the Gramm-Leach-Bliley Act. Requirements under the Act include but are not limited to:

  • Providing our clients with annual notices detailing our use of their NPI and offering them the option of "opting-out" of any disclosure of their NPI to affiliated or non-affiliated persons/firms.
  • Providing prospective clients with an initial notice detailing our use of their NPI and offering them the option of "opting-out" of any disclosure of their NPI to affiliated or non-affiliated persons/firms.
  • Protecting personal information about our current and past customers by not disseminating information to any outside parties except as required/permitted by law or requested by the client.
  • Protecting personal information about our current and past customers from accidental dissemination / theft by maintaining adequate security of information, be it in paper or electronic format.

The Privacy Policy will be updated annually or as necessary by the Firm Principals.

Brandywine Asset Management, Inc.
The Mill
381 Brinton Lake Road
Thornton, PA 19373
610-361-4000

Disclaimer:
PAST PERFORMANCE IS NOT INDICATIVE OF FUTURE PERFORMANCE. THERE IS THE RISK OF LOSS AS WELL AS THE OPPORTUNITY FOR GAIN WHEN INVESTING WITH BRANDYWINE.