Notice of Privacy Practices of Fayez Sarofim & Co. and its Affiliates

Fayez Sarofim & Co. and its Affiliates

Sarofim International Management Company
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 personal information.
  • 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 ;
  • 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 ) ; or
  • If such disclosure has been expressly consented to by you or your authorized representatives;
  • 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