Disclosures

Cleary Gull has adopted a Code of Ethics to assist employees in carrying out its duties as a fiduciary to its clients. The Code of Ethics is based upon the principle that Cleary Gull and its employees owe a fiduciary duty to clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid: (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the firm, and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. The Code of Ethics is designed to maintain Cleary Gull’s high ethical standards. Existing or prospective clients may contact Cleary Gull for a full copy of the Code of Ethics.

We consider privacy as fundamental to the relationship with our clients. Accordingly, we have developed policies and procedures to protect the confidentiality, integrity and security of client information and to help achieve compliance with relevant rules and regulations. We hold our employees accountable for complying with those policies, procedures, rules and regulations

Information We May Collect

We endeavor to collect, use and maintain client information only for appropriate purposes.  We may collect and maintain the following nonpublic personal information about you:

•  Ÿinformation we receive from you on applications or other forms, such as your name, address, email address, tax identification number, telephone number, account number, and other relevant account information; and

• Ÿinformation about your transactions with us, our affiliates or others, such as your account number, balance, positions, activity, history, and other financial information.

Information We May Disclose or Share

We do not disclose any nonpublic personal information about our clients or former clients to any third parties, except as permitted or required by law or for the purposes of servicing client needs.  We are permitted by law to share any of the information we collect, as described above, with our affiliates.  Cleary Gull will share information with affiliates if the information is required to provide a product or service you have requested.  We may also share your personal information relating to transactions and experiences with affiliates for their everyday business purposes.  In addition, we may share information about clients or client accounts with affiliates in order to make clients aware of services that Cleary Gull thinks may be of interest or value to them.  Marketing from our affiliates may also include invitations to events.
 
We may share information with non-affiliated third parties to the extent necessary to effect, process, administer or enforce a transaction that you request or authorize, in connection with maintaining or servicing your account, as requested by regulatory authorities, or as otherwise permitted or required by law.  For example, we may provide such information to companies that perform various services such as auditors, attorneys, outside investment managers, or custodians.  We may also disclose information to non-affiliated parties if compelled by law, such as responding to a subpoena, preventing fraud, or complying with an inquiry by a government agency or regulator.
 
How We Protect Your Information

We restrict access to nonpublic personal information about you to those persons who need to know that information to provide services to you.  We maintain physical, electronic, and procedural safeguards to protect the confidentiality, integrity, and security of your nonpublic personal information.  Any party that accepts or receives nonpublic personal information from us is obligated by contract or by law or regulation to keep this information confidential and to use the information only for those purposes that we specify or as required.

We will continue to adhere to the privacy policies and practices in this notice even if your account is closed or becomes inactive.

Affiliate Marketing Opt-Out

Clients may limit Cleary Gull’s affiliates from marketing their services based on personal information that we collect and share with them.  Your choice to limit marketing offers from our affiliates will apply until you request a change to your choice.  If you have already made a choice to limit marketing offers from our affiliates, you do not need to act again.

How to Contact Cleary Gull

To limit marketing offers or for questions about our privacy policy, please contact Cleary Gull at 888-349-1600 or by mail at 100 East Wisconsin Avenue, Milwaukee, WI  53202.

Customer Identification – Important Information about Procedures for Opening a New Account
To help the government fight the funding of terrorism and money laundering activities, federal law requires certain financial institutions, including Cleary Gull as the introducing broker to your investment account custodied at RBC Correspondent Services, to obtain, verify, and maintain information that identifies each person who opens an account. To meet this federal obligation, we will ask for your name, address, date of birth (for an individual), and an identification number or articles of incorporation that will allow us to verify your identity. We may also ask for a driver’s license or other identifying documents. This process may include the use of third party sources to verify the information provided.

For accounts owned by a trust, customer identification procedures may require Cleary Gull to obtain a copy of a trust instrument. Any trust instrument will be retained solely for the purposes of customer identification as required by law, and Cleary Gull accepts no responsibility for the enforcement or administration of any of the terms thereof.

Business Continuity Planning

In accordance with regulations, Cleary Gull has developed a business continuity plan that is intended to permit us to continue, or quickly recover and resume, critical business operations during natural disasters, power outages, or other significant events. While there can be no assurance that service will continue without interruption in all circumstances, our plan does address the actions that we will take in the event that there is a significant business disruption.

Our plan addresses:

• data backup and recovery
• mission critical systems
• financial and operational assessments
• alternative communications with customers, employees and regulators
• alternate physical location of employees
• critical supplier, contractor, bank and counter-party impact
• regulator reporting
• assuring clients prompt access to their funds and securities if we are unable to continue our business
• any entities the firm may rely on for certain procedures and/or mission critical systems

Because our plan contains details of a confidential and proprietary nature, it is not distributed to the public.

Contacting Us: In the event of a significant business disruption, you can obtain up-to-date information regarding the operating status of our firm on this website. In the event you cannot contact us or obtain up-to-date information from this website, you should contact your account custodian who will assist you in accessing your funds and securities and/or processing account transactions.

Order Routing Information – SEC Rule 606 Disclosure

SEC Rule 606 requires all broker-dealers that route orders on behalf of customers to make available quarterly reports that present a general overview of their routing practices. The reports must identify the significant venues to which the customer orders were routed for execution and disclose the material aspects of the broker-dealer¹s relationship with such venues.

Cleary Gull routes the majority of equity transactions to RBC and has determined that the RBC order routing is representative of Cleary Gull customer transactions.

Please click here to view the RBC Report on Routing of Customer Orders for the current quarter.

Customer Request for Order Routing Information

Upon request, Cleary Gull will provide you with the identity of the venue to which your orderse were routed for execution in the six months prior to the requests, whether the orders were directed orders or non-directed orders, and the time of the transactions, if any, that resulted from such orders.

Cleary Gull
100 East Wisconsin Avenue
Suite 2400
Milwaukee, WI 53202

Important Legal Information*
By using this site, you signify your assent to, and agree to be bound by, the following terms and conditions. You should read these conditions carefully before using this site, and if you do not agree to these terms, you should exit this site. These terms may be amended at any time. Cleary Gull provides this site for informational purposes. Nothing on this site should be construed as an offer or solicitation to buy or sell any securities, futures, options or other financial instruments or provide any investment advice or service.

Disclaimer of Warranty and Limitation of Liability
The information on this site is provided “as is”. Cleary Gull does not warrant the accuracy of the materials provided herein, either expressly or by implication, for any particular purpose and expressly disclaims any warranties of merchantability or fitness for a particular purpose. Cleary Gull will not be responsible for any loss or damage that could result from interception by third parties of any information made available to you via this site.

Although the information provided to you on this site is obtained or compiled from sources we believe to be reliable, Cleary Gull cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose.

Neither Cleary Gull, nor any of its affiliates, directors, officers or employees, nor any third party vendor will be liable or have any responsibility of any kind for any loss or damage, of any kind or nature, that you incur in the event of any failure or interruption of this site, or resulting from the act or omission of any other party involved in making this site or the data contained therein available to you, or from any other cause relating to your access to, inability to access, or use of the site or such data, whether or not the circumstances giving rise to such cause may have been within the control of Cleary Gull or of any vendor providing software or services support. In no event will Cleary Gull, its affiliates or any such parties be liable to you for any direct, special, indirect, consequential, incidental damages or any other damages of any kind even if Cleary Gull or any other party have been advised of the possibility thereof.

Use of Content
Cleary Gull owns this website, and permission is given to display and navigate this site for personal use only. You may download material displayed on this site for non-commercial, personal use only, provided you also retain all copyright and other proprietary notices contained on the materials.

Use of Links
If you leave this site via a link contained herein, you do so at your own risk. The content to which you link will not have been developed, checked for accuracy, or otherwise reviewed by Cleary Gull. Cleary Gull is not responsible for damages or losses caused by any delays, defects or omissions that may exist in the services, information or other content provided in such site, whether actual, alleged, consequential or punitive. Cleary Gull makes no guarantees or representations as to, and shall have no liability for, any electronic content delivered by any third party, including, without limitation, the accuracy, subject matter, quality or timeliness of any electronic content.

Procedure for Making Claims of Copyright Infringement
Cleary Gull respects the intellectual property of others and asks that you do the same. If you believe that your copyrighted work is accessible on this site in a way that constitutes copyright infringement, you may notify us by providing our Copyright Agent with the following information: 1) the electronic or physical signature of the owner of the copyright or of the person authorized to act on the owner’s behalf; 2) a description of the copyrighted work that has allegedly been infringed; 3) identification of the specific location on this site where that work is located; 5) your name, address, telephone number, and email address; 6) a statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner’s behalf. The agent of Cleary Gull for claims of copyright infringement on this site is wbraun@clearygull.com.

Governing Law
These Terms of Use shall be governed by and construed in accordance with the laws of Wisconsin, without giving effect to any principles of conflicts of law. If you take legal action arising out of or relating to these terms and conditions, you agree to file such action only in the state or federal courts, and you hereby consent and submit to the personal jurisdiction of such courts for the purposes of litigating any such action*. If any provision of these terms is deemed unlawful, void, or for any reason unenforceable, then that provision shall be deemed severable from these terms and shall not affect the validity and enforceability of any remaining provisions. This is the entire agreement between Cleary Gull Holdings and the user relating to the subject matter herein.

Cleary Gull
100 East Wisconsin Avenue
Suite 2400
Milwaukee, WI 53202