Privacy Statement

WJ is committed to safeguarding your confidential information. We hold all personal information provided to our firm in the strictest confidence.

  • We have never disclosed information to nonaffiliated third parties, except as permitted by law, and do not anticipate doing so in the future. We are prohibited by law to do so without advising you first.
  • We limit access to information only to those who have a business or professional reason for knowing, and only to nonaffiliated parties as permitted by law. For example, federal regulations permit us to share a limited amount of information about you with a brokerage firm to execute securities transactions on your behalf, or so that we can discuss your financial situation with your accountant or lawyer.
  • We maintain a secure office and computer environment to ensure that your information is not placed at unreasonable risk.
  • The types of personal information that we ask for depend upon the specifics of your portfolio. It may include information about your personal finances, your health to the extent that it is needed for the planning process, transactions between you and others, and information from consumer reporting agencies.
  • For unaffiliated third parties that require access to your personal information, such as financial service companies, consultants, and auditors, we require strict confidentiality in our agreements with them and expect them to keep your information private. Federal and state regulators also may review firm records as permitted under the law.
  • We do not provide your personally identifiable information to mailing list vendors or solicitors for any purpose.
  • Your information is kept while you are a client, and after for as long as is required by federal and state securities laws. It is destroyed after all recordkeeping requirements have been met.

Personal conduct rule

WJ also has established a personal conduct rule to avoid any actual or perceived conflict with clients that addresses:

  • Giving and receiving gifts.
  • Serving as director for an outside company.
  • Outside business interests.

In addition, new employees must acknowledge that they have read, understand and agree to comply with the Code of Ethics, personal trading policy and personal conduct rule. All employees are required to renew this acknowledgement each year in connection with WJ’s annual compliance practices.

Personal trading policy

  • Employees are required to know which securities are being traded by WJ, and are encouraged to consult with Jared Jameson to determine if a personal trade would be appropriate.
  • Employees must receive approval from Jared Jameson before investing in an initial public offering (IPO) or an equity position within a non-public company. Jared will receive approval from Bill Jameson before approving the investment.
  • Employees are required to report all their personal securities transactions and holdings each quarter. This includes the personal securities information of any family member living within the same household as the employee.
  • Employees may hold or trade the following securities, which are considered safest for an employee to purchase, sell or hold from a regulatory perspective, both for WJ and the employee:
    • Shares of open-end mutual funds.
    • Shares of any money market fund.
    • Direct obligations of the US Government.
    • Money market instruments, such as bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high-quality, short-term debt.

Review of personal transactions

Jared Jameson will generally consider the following factors when reviewing reportable security holdings and transactions or approvals by employees to purchase IPOs or private placements:

  • Whether the investment opportunity should be directed to a client’s account.
  • Whether the amount or nature of the transaction affected the price or market for the security.
  • Whether the purchases or sales being made for clients benefited the employee.
  • Whether the transaction harmed any client.
  • Whether the transaction has the appearance of impropriety.

Violations

All employees are required to promptly report any violation of this policy to Jared Jameson, including the discovery of any violation committed by another employee. Examples of items that should be reported include noncompliance with federal securities laws, conduct that is harmful to clients and purchasing securities contrary to the personal trading policy.

Employees are encouraged to report any violations or apparent violations. Such reports will not be viewed negatively by firm management, even if the event is determined not to be a violation, but that it was reported in good faith.

Sanctions

If an event is determined to be a violation of this policy, sanctions may be imposed, including loss of profits, reversal of the trade or suspension of trading privileges.