Shepherd Kaplan LLC Confidentiality Disclosure

Shepherd Kaplan holds both our firm and our employees to the highest standards of trust and fiduciary duty in the safekeeping and use of our clients' personal and financial data. To that end, we remain committed to maintaining the confidentiality of information we collect regarding our relationship with our clients (including current, former, and potential clients), and adhere to the following privacy policies and practices with regard to all client relationships:

1. We do not give or sell any non-public, personal information to any individual, company or group, except as stated below.
2. We may receive non-public, personal information, such as personally identifying data and financial information, about our clients from the clients and from financial and information service and consumer reporting firms when clients engage us or when we assist clients in opening investment accounts. We also exchange such information with custodians, investment managers, brokers and other nonaffiliated financial service providers as required or permitted by law in the course of providing services for the client.
3. All information regarding Shepherd Kaplan's clients is treated confidentially. Such information may only be disclosed when the disclosure is consistent with the firm's policy and the client's direction. Shepherd Kaplan does not share confidential client information with any third parties, except with the client’s consent or in the following circumstances:
   
   
   • As necessary to provide the services that the client has requested or authorized, or to maintain and service the client's account;
   • As required by regulatory authorities or law enforcement officials who have jurisdiction over Shepherd Kaplan, or as otherwise required by any applicable law; and
   • To the extent reasonably necessary to prevent fraud, unauthorized transactions, claims or other liability.
4. We restrict access to confidential client information to only those Shepherd Kaplan employees who need to know that information to provide service to Shepherd Kaplan‘s clients.
5. We maintain physical, electronic, and procedural safeguards to protect confidential client information.
6. Employees with access to confidential client information may not use or disclose the information except for Shepherd Kaplan business use. All of our employees are required to safeguard such information as specified in their signed confidentiality agreements with Shepherd Kaplan.
7. When there is a need to dispose of confidential client information, we require our employees to shred, not discard, the data.
8. We continue to evaluate our efforts to protect confidential client information and make every effort to keep our privacy policy and practices accurate and current.