NOTICE OF PRIVACY PRACTICES
Fayez Sarofim & Co. and its Affiliates
Sarofim International Management
Sarofim Trust Co.
Sarofim Realty Advisors Co.
Sarofim Advisors Group, Inc.
Fayez Sarofim &
Co. (the “Company”) and its “affiliates” listed above (collectively,
the “Sarofim Affiliates”) have always been committed to maintaining
the strict confidentiality of personal information regarding their
clients and their clients’ accounts. Each of the Sarofim Affiliates
is an investment adviser registered with the U.S. Securities and
Exchange Commission (“SEC”). Thus, in addition to adherence to this
long-standing policy, the Sarofim Affiliates are subject to rules
governing privacy of consumer financial information adopted by the
SEC (the “SEC Rules”). The SEC Rules, among other things, require
that registered investment advisers, such as the Sarofim Affiliates,
provide initial and annual privacy notices to their clients. This
Notice is provided in satisfaction of such requirement.
The Sarofim Affiliates (sometimes
referred to in this Notice as “we” or “us”) value our relationship
with you and we recognize that an essential element of that relationship
is your trust and confidence that the information you share with
us will be treated as private and confidential to the extent permitted
or required by law.
Set forth below in “bullet” or summary form
is a statement of practices we follow in the collection, disclosure
and protection of information about you.
Your “nonpublic personal
information”. As part of our investment advisory and
investment management business (and as part of the trust and custodial
businesses of Sarofim Trust Co.), we obtain certain information
about you, such information being defined in the SEC Rules as “nonpublic
personal information”. We obtain “nonpublic personal information”
about you from the following sources: (i) information we receive
from you in meetings and conferences, on applications and other
forms, in contracts or documents, and in correspondence, including
electronic mail, and (ii) information about your transactions with
us, our affiliates, including the Sarofim Affiliates or others.
Access to and protection
and distribution of your nonpublic personal information.
We have adopted and comply with policies and procedures to safeguard
your nonpublic personal information. Access to your nonpublic personal
information (and the nonpublic personal information of any other
client, past or present) is restricted by us to only those authorized
individuals who need to know this information in order for us to
provide services or products to you. However, we distribute certain
information regarding your account to you or your authorized representative
or representatives, from time to time by United States mail, postage
prepaid, addressed to your address of record furnished to us by
you or your authorized representative or representatives, such distributed
information including letters advising about transactions effected
for your account, periodic account statements showing holdings,
transactions and other data, and other investment information and
analysis. We will distribute this information to an electronic mail
address if you or your authorized representative or representatives
authorize us to do so and you and your authorized representatives
comply with our then current policies and procedures relating to
such distribution. With respect to either method of dissemination,
there are certain risks that your nonpublic personal information
could be intercepted or accessed by unauthorized persons. W e maintain
physical, electronic, and procedural safeguards that comply with
federal standards to guard and otherwise protect your nonpublic
General disclosure policy.
We may disclose your confidential information (or the confidential
information of any other client, past or present) on a limited basis
to certain nonaffiliated third parties, but only:
If such disclosure is necessary to
process and service your account, including process and service
transactions which you have requested or authorized and to report
to you regarding transactions in and the performance of your account
If such disclosure has been expressly
consented to by you or your authorized representatives;
Where there is not a processing disclosure,
if such disclosure is permitted by law (examples of these types
of disclosures being disclosures (i) to protect the confidentiality
or security of our records relating to you, our services or our
transactions, (ii) to protect against or prevent actual or potential
fraud, unauthorized transactions, claims or other liability , and
(iii) in response to proper subpoenas or other legal process ) ;
If such disclosure (i) is to nonaffiliated
third parties which perform services on our behalf and (ii) is the
subject of a written agreement with such parties pursuant to which
such parties have agreed to keep all information furnished to them
confidential and secure except as permitted by law.
You do not need to take
any action as a result of this Notice. This Notice is meant to confirm
our confidentiality commitment to you as part of maintaining the
essential element of trust in our relationship. We value our relationship
with you and strive to earn your continued trust. If you have any
question or concern, you may contact your account executive or Mrs.
Raye G. White, Executive Vice President of Fayez Sarofim & Co.
Effective as of March 31, 2006