Privacy
Wellington Management respects the privacy of, and confidentiality with respect to information pertaining to, its clients and acts to meet the expectations of its clients in this regard.
Information Sharing
The Wellington Management organization contains a variety of companies dedicated to serving a particular aspect of a client’s investment management needs. Wellington Management strives to provide seamless service to all of its clients, whether they call upon functions performed by one or several Wellington Management companies. To facilitate that process, information regarding client accounts is shared broadly within the organization. For example, the affiliates share information with the parent company in order to facilitate portfolio management. The parent also shares information with the affiliate that provides client service to a particular client. Finally, client information may be used by different entities in the organization in order to identify potential client needs for additional investment management services.
In contrast, Wellington Management typically does not share nonpublic client information with unaffiliated third parties other than as necessary to carry out the actual performance of the investment management services it has been hired to provide. Thus, for example, Wellington Management will share nonpublic client information with brokers and custodian banks in order to buy and sell securities and record those purchases and sales accurately. As a general rule, Wellington Management does not engage in joint marketing arrangements with unaffiliated third parties that involve the sharing of nonpublic information regarding Wellington Management’s clients. Nor does it sell client information to unaffiliated third parties for their own marketing purposes. Any exceptions to these practices are made only with the permission of the particular client for the sharing of information with identified third parties or as otherwise required by law.
Physical Security
Wellington Management recognizes the need to provide a secure environment for nonpublic client information, whether that information is maintained in physical or electronic form. In addition to building security provided by its landlords, Wellington Management employs various measures to protect the security of the firm’s offices. Receptionists in each office monitor the entry of visitors to the office and are trained on procedures for dealing with unauthorized individuals. Entrances that are not staffed with receptionists can be accessed only with an authorized access control card, which is controlled by the Wellington Global Security Department. The security system is governed by internal security controls and is reviewed by Security Management. Access to certain areas containing sensitive information is further restricted within the firm by means of the access control card to those partners and employees with a need to access the restricted area. This access is granted by the business owner of the area. The firm monitors the use of access cards and deactivates the access of former partners and employees immediately upon termination or if a partner or employee transfers to a different business area or changes job positions.
Electronic Security
Wellington Management’s Information Services Group has dedicated staff responsible for maintaining the security of the firm’s electronic data, including data regarding specific client accounts. The Information Services Group regularly assesses the measures employed to protect the firm’s network against unauthorized access to its data by outsiders, and implements systems designed to prevent unwanted intrusions. Those systems are monitored continuously. Potential security breaches are investigated and resolved on a high priority basis.
In addition to the general security measures designed to prevent unauthorized access to the Wellington Management network, many of the firm’s critical databases have further internal password protection. Partner and employee access is controlled by the Information Services Group and must be authorized in advance by appropriate managers based upon the individual’s need for access to the database in order to perform his or her job responsibilities. When an individual moves out of a job in which such access is necessary, his or her access rights are terminated. The Information Services Group has designed enhanced security measures to provide additional protection for certain highly confidential network applications.
Web Site Security
Wellington Management’s secure web sites for reporting account information to Wellington Management clients have additional security features designed to protect against unauthorized access to client information. The web sites themselves can be accessed only through the use of a Wellington Management-issued password. As with all other pieces of the Wellington Management network, the Information Services Group continually assesses the efficacy of the security measures being employed in the web sites and will upgrade security as it deems appropriate.
We reserve the right to change our Privacy policies, and any of the policies described herein, at any time. The examples contained in this statement are illustrations; they are not intended to be exclusive.