Confidential Client Information

In the course of investment advisory activities of Sovereign Wealth Management, Inc., the firm gains access to non-public personal information about its clients.  Such information may include a person's status as a client, personal financial and account information, date of birth, social security number, sources and amounts of income, the allocation of assets in a client portfolio, the composition of investments in any client portfolio, information relating to services performed for or transactions entered into on behalf of clients, advice provided by Sovereign Wealth Management, Inc. to clients, and data or analyses derived from such non-public personal information (collectively referred to as "Confidential Client Information").  All Confidential Client Information, whether relating to Sovereign Wealth Management, Inc.'s current or former clients, is subject to this privacy policy.  Any doubts about the confidentiality of information must be resolved in favor of confidentiality.

Non-Disclosure of Confidential Client Information

All information regarding Sovereign Wealth Management, Inc.'s clients is confidential.   Information may only be disclosed when the disclosure is consistent with this policy and the client's direction, except as permitted by law.  Sovereign Wealth Management, Inc. does not disclose any Confidential Client Information with any third parties, except in the following circumstances:

  • As necessary to provide service that the client requested or authorized, or to maintain and service the client's account.  Sovereign Wealth Management, Inc. will require any financial intermediary, agent or other service provider utilized by Sovereign Wealth Management, Inc. (such as broker-dealers or sub-advisers) to comply with substantially similar standards for non-disclosure and protection of Confidential Client Information and use the information provided by Sovereign Wealth Management, Inc. only for the performance of the specific service requested by Sovereign Wealth Management, Inc.

  • As required by regulatory authorities or law enforcement officials who have jurisdiction over Sovereign Wealth Management, Inc., or as otherwise permitted by law.  In the event Sovereign Wealth Management, Inc. is compelled to disclose Confidential Client Information, the firm shall provide prompt notice to the clients affected, so that the clients may seek a protective order or other appropriate remedy.  If no protective order or other appropriate remedy is obtained, Sovereign Wealth Management, Inc. shall disclose only such information, and only in such detail, as is legally required

  • To the extent reasonably necessary to prevent fraud, unauthorized transactions or liability.

Employee Responsibilities

All employees are prohibited during and after the termination of their employment with Sovereign Wealth Management, Inc., from disclosing Confidential Client Information to any person or entity outside the firm, including family members, except under the circumstances described above.  An employee is permitted to disclose Confidential Client Information only to such other employees who need to have access to such information to deliver Sovereign Wealth Management, Inc.'s services to the client.Employees are also prohibited from making unauthorized copies of any documents or files containing Confidential Client Information. Upon termination of their employment with Sovereign Wealth Management, Inc., all employees must return all such documents to Sovereign Wealth Management, Inc.Any employee who violates the non-disclosure policy described above will be subject to disciplinary action, including possible termination, whether or not he or she benefited from the disclosed information.

Security of Confidential Personal Information

Sovereign Wealth Management, Inc. enforces the following policies and procedures to protect the security of Confidential Client Information:The firm restricts access to Confidential Client Information to those employees who need to know that information to provide Sovereign Wealth Management, Inc.'s services to clients; Any employee who is authorized to have access to Confidential Client Information in connection with the performance of such employee’s duties and responsibilities is required to keep such information in a secure compartment, file or receptacle on a daily basis as of the close of each business day; All electronic or computer files containing any Confidential Client Information are password secured and firewall protected from access by unauthorized persons; Any conversations involving Confidential Client Information, if appropriate at all, must be conducted by employees in private, and care must be taken to avoid any unauthorized persons overhearing or intercepting such conversations.In the event supervisors or employees are not completely confident of client’s identity, additional questions may be asked by any employee (e.g., social security number, primary personal residence, or specific account numbers) to confirm that claimed identity.

Privacy Policy

As a registered investment adviser, Sovereign Wealth Management, Inc. and all employees must comply with SEC Regulation S-P, which requires investment advisers to adopt policies and procedures to protect the "nonpublic personal information" of consumers.  "Nonpublic information," under Regulation S-P, includes personally identifiable financial information and any list, description, or grouping that is derived from personally identifiable financial information that is not publicly available information.  “Personally identifiable financial information” is defined to include information provided by clients, information resulting from transactions, any information obtained in providing products or services.  Pursuant to Regulation S-P Sovereign Wealth Management, Inc. has adopted policies and procedures to safeguard the information of its clients.

Enforcement and Review of Confidentiality and Privacy Policies

The Chief Compliance Officer is responsible for reviewing, maintaining and enforcing Sovereign Wealth Management, Inc.'s confidentiality and privacy policies and is also responsible for conducting appropriate employee training to ensure adherence to these policies.  Any exceptions to this policy require the written approval of the Chief Compliance Officer.