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Privacy Policy

Introduction

Brandywine Global may be required by applicable laws and regulation to provide this Privacy Notice to you. Brandywine Global operates in a number of jurisdictions around the world and as such is required to provide specific information to residents in those jurisdictions. Our Global Policy below applies to all individuals that interact with Brandywine Global whether in person or through electronic communications, including our website.

 

Global Policy

It is the policy of Brandywine Global to institute appropriate procedures, processes, and systems to safeguard the integrity, confidentiality, and security of client (or potential client) and Customer non-public information (“Non-Public Information”) and protect such information from unauthorized use or disclosure.

 

Definitions

For the purpose of this policy:

Non-Public Information at the highest level is information relating to clients, potential clients, or customers, that is not publicly available. This also includes any “sensitive customer information” as defined in Regulation S-P.

Customer is defined as an individual, or their legal representatives, who obtain or have obtained financial products or services from Brandywine Global primarily for personal, family, or household services.

Sensitive Customer Information is any component of Customer information alone or in conjunction with any other information, the compromise of which could create a reasonably likely risk of substantial harm or inconvenience to an individual identified with the information.  The definition is meant to include types of information that, if exposed, could put affected individuals at a higher risk of suffering substantial harm or inconvenience through, for example, fraud or identity theft enabled by the unauthorized access to or use of information (i.e. social security number, driver’s license number, passport, etc.).

 

Disclosure of Non-Public Information to Non-Affiliated Third Parties

At a minimum, Non-Public Information will not be disclosed to non-affiliated third parties, subject to the following exceptions:

  • Non-Public Information may be disclosed to non-affiliated third parties to perform services on behalf of Brandywine Global if Brandywine Global has entered into a contractual agreement with the third party that prohibits the third party from disclosing or using the information other than to carry out the defined services.
  • Non-Public Information may be disclosed to non-affiliated third parties as necessary to effect, administer, or enforce a transaction that a client requests and authorizes.
  • Non-Public Information may be disclosed to non-affiliated third parties with the consent or at the direction of the data owner.
  • Non-Public Information may be disclosed to non-affiliated third parties as may otherwise be required by law.

 

Receipt of Non-Public Information from Non-Affiliated Third Parties

If Brandywine Global receives Non-Public Information relating to its clients or prospective clients from a non-affiliated third party, Brandywine Global will treat such information in the same manner as it would any other Non-Public Information in its possession in accordance with this Policy.

 

Service Provider Oversight

Brandywine Global’s parent company, Franklin Resources, provides corporate and operational services to Brandywine Global, including oversight of Service Providers. Frankin Resources has established, maintains, and enforces written policies and procedures reasonably designed to perform oversight, including through due diligence and monitoring, of service providers and to ensure risks are identified, mitigated, and managed through all stages of a service provider relationship.

The policies and procedures are reasonably designed to ensure service providers take appropriate measures to protect against unauthorized access to or use of customer information, and provide notification to Franklin Resources as soon as possible, but no later than 72 hours after becoming aware that a breach in security has occurred resulting in unauthorized access to a customer information system maintained by the service provider.

Franklin Templeton’s Enterprise Supplier Risk Management Policy and Global Enterprise Vendor Management & Strategic Sourcing Policy are incorporated by reference herein and available upon request.

 

Safeguarding Non-Public Information

Brandywine Global has adopted Franklin Resources’ Corporate Information Security Policy that addresses administrative, technical, and physical safeguards for the protection of Non-Public Information. These procedures are designed to reasonably ensure (i) the security and confidentiality of Non-Public Information; (ii) protection against anticipated threats or hazards to security or integrity of Non-Public Information; and (iii) the prevention of unauthorized access to or use of Non-Public Information that could cause substantial harm or inconvenience to clients or customers.

Franklin Resources’ Corporate Information Security Policy is incorporated by reference herein and available upon request.

 

Incident Response Program

Brandywine Global has adopted Franklin Resources’ Cyber Security Incident Response Plan managed by Global Information Security (GIS), and the Privacy Incident Response Plan, managed by the Global Privacy Office (GPO). Franklin Resource’s Incident Response program is designed to detect, respond to, and recover from unauthorized access to or use of customer information (an “incident”). This program includes:

  • Assessing the scope and nature of any incident, including which customer information systems and customer information may have been accessed or used without authorization.
  • Containing and controlling the incident to prevent further unauthorized access or use.
  • Notifying affected individuals whose sensitive customer information was, or is reasonably likely to have been, accessed or used without authorization unless the covered institution determines, after a reasonable investigation of the facts and circumstances of the incident, that the sensitive customer information has not been, and is not reasonably likely to be, used in a manner that would result in substantial harm or inconvenience.

All suspected or actual incidents are required to be reported to GIS and the GPO, or in accordance with escalation procedures approved by those functions, to ensure they are handled in accordance with the company’s established incident response procedures.

 

Recordkeeping Requirements

Brandywine Global will retain written records under Regulation S-P, including those related to safeguards, disposal, incident response, and service provider oversight, for six years, with the first two years in an easily accessible place.

 

Disposal of Non-Public Information

Brandywine Global will properly dispose of any Non-Public Information and as required by International Data Protection laws as follows:

Hard Copy Media: In accordance with all applicable rules and regulations, Brandywine Global, in conjunction with Franklin Resources, will shred or arrange for the secure destruction of all hard copy media containing Non-Public Information.

Electronic Media: In accordance will all applicable rules and regulations, Brandywine Global, in conjunction with Franklin Resources, will destroy or arrange for the secure destruction of all company electronic media.

 

Cookies and Similar Tracking Technologies

We use essential (or strictly necessary) cookies to run our site.  With your permission, we’ll also use cookies and other tracking technologies to analyze website usage, improve performance, personalize your experience, deliver personalized ads, and support marketing efforts.  Non-essential cookies remain off until you choose Accept All or enable them in Manage Settings.

You can continue with essential-only and change choices anytime. For more information, view our Privacy & Cookies Notice.

 
 

Changes to Our Privacy Policy

We keep our privacy policy under regular review. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you. Please check back frequently to see any updates or changes to our privacy policy.

If you are a current client, we will inform you in writing of any material modifications made to this Policy. In any event, we will deliver our Privacy Policy to you at least annually.

 

Contact Us

Please contact us if you have any questions about our privacy policy or Non-Public Information we hold about you.

Write to:

Privacy
Brandywine Global Investment Management, LLC
1735 Market Street, Suite 1800
Philadelphia, PA 19103
USA

By email: [email protected]

By phone: 800 348 2499

Residents of the United Kingdom and/or the European Union Click Here
Residents of Singapore Click Here

General Disclaimers: This material has been prepared by Brandywine Global Investment Management, LLC ("Brandywine Global") and is provided to certain qualified institutions, financial intermediaries, and institutional investors for informational purposes only. It may not be reproduced or redistributed without Brandywine Global's prior written approval. This material is not intended to be a forecast, research, or investment advice, and is not a recommendation, or an offer or solicitation to buy or sell any securities or to adopt any particular investment strategy. The information set forth herein has been derived from sources believed to be accurate, reliable, and current as of the date of this material, but is subject to change without notice. The opinions expressed may differ from those of other Brandywine Global portfolio management teams and our affiliates. References to specific securities, asset classes and financial markets are for illustrative purposes only and are not intended to be, and should not be, interpreted as recommendations. The material was prepared without regard to specific objectives, financial situation or needs of any investor and should not be used as the basis of any investment decision.

Risk: All financial investments involve an element of risk. Past performance does not guarantee future results. The value of investments and the income derived from investments will fluctuate and a loss of principal can occur.

Foreign securities, foreign currencies, and securities issued by U.S. entities with substantial operations outside of the U.S. can involve additional risks relating to political, economic, or regulatory conditions in foreign countries. These risks include market/currency fluctuations, withholding or other taxes, trading, settlement, custodial, and other operational risks, and less stringent investor protection and disclosure standards in some foreign markets. All of these factors can make foreign investments, especially those in emerging markets, more volatile and potentially less liquid than U.S. investments. In addition, foreign markets may perform differently from the U.S. market.

Transactions in any option, future, commodity, or other derivative product is not suitable for all persons and accordingly, investors should be aware of the risks involved in trading in such instruments. Transactions in derivatives have the potential to increase liquidity risk and introduce other significant risk factors of a complex character. All securities trading, whether in stocks, options, or other investment vehicles, is speculative in nature and involves substantial risk of loss. No assurance, representation, or warranty is made by any person that any of the aims, assumptions, expectations, objectives, and/or goals stated herein will be achieved. Nothing contained in this material may be relied upon as a guarantee, promise, assurance, or representation as to the future.

Fixed income securities are subject to the risks associated with debt securities generally, including credit, liquidity and interest rate risk. High yield and lower-rated fixed income securities involve greater risk than investment-grade securities. Asset-backed, mortgage-backed or mortgage related securities are subject to additional risks such as prepayment and extension risks. High yield bonds possess greater price volatility, illiquidity, and possibility of default.

Equity investments are subject to market risk. The value of investment may fluctuate in response to the prospects of individual companies, particular sectors, and/or general market conditions. Investments in in speculative and/or small-cap, mid-cap and micro-cap companies may involve a higher degree of risk and volatility than investments in larger, more established companies, including such risks as lack of product diversification, potentially insufficient capital resources and greater exposure to business and economic cycles.

Portfolio Structure: Each client’s portfolio is individually managed and may vary from the information shown in terms of allocations, portfolio holdings, characteristics, and performance. Current and future portfolio compositions and performance may be significantly different. Any securities, sectors or allocations referenced may or may not be represented in portfolios of clients of Brandywine Global, and do not represent all of the securities purchased, sold, or recommended for client portfolios. The reader should not assume that any investments in securities, sectors and/or markets identified or described were or will be profitable or that similar investments will be available in the future.

Outlook: Economic and market forecasts presented herein reflect a series of assumptions and judgments as of the date of this material and are subject to change without notice. These forecasts do not take into account the specific investment objectives, restrictions, tax and financial situation or other needs of any specific client. Actual data will vary and may not be reflected herein. These forecasts are subject to high levels of uncertainty that can affect actual performance. Accordingly, these forecasts should be viewed as merely representative of a broad range of possible outcomes. These forecasts are estimated, based on assumptions, and are subject to significant revision and may change materially as economic and market conditions change. Certain information or statements contained herein may constitute a forward-looking statement. Forward- looking statements are predictive in nature and speak only as of the date they were made. Brandywine Global assumes no duty to and does not undertake to update forward-looking statements. Forward-looking statements refer to future events or conditions and are subject to a number of assumptions, risks and uncertainties that could cause actual results or events to differ materially from current expectations.

Third-Party Ratings: Any unpublished third-party rankings, awards or similar groupings have inherent limitations and qualifications, and are not indicative of the experience of any client or investor or of the future performance of any product described herein. There can be no assurance that the universe upon which the ratings or awards were based included all investment products within each category that are actually in operation or existence. The investment products on which the ratings were based may differ substantially in terms, objective, strategy, target risk return profile and certain other significant respects from those referenced herein.

Indices/Benchmarks: Indices are unmanaged and are not available for direct investment. Indices are not subject to fees and expenses typically associated with separate accounts or investments in funds. References to indices, benchmarks or other measures of relative market performance over a specified period of time are provided for your information only and do not imply that the portfolio will achieve similar results. The index composition may not reflect the manner in which a portfolio is constructed. While an adviser seeks to design a portfolio which reflects appropriate risk and return features, portfolio characteristics may deviate from those of the benchmark.

Selection of Representative Account: Representative accounts are generally the least restrictive account in a composite at the time of selection. Each client account is individually managed; individual holdings will vary for each account and there is no guarantee that a particular account will have the same characteristics as described. Actual results may vary for each client due to specific client guidelines, holdings, and other factors. In limited circumstances, the designated representative account may have changed over time, for reasons including, but not limited to, account termination, imposition of significant investment restrictions, or material asset size fluctuations.

Environmental, Social and Governance (“ESG”): This material discusses Brandywine Global’s current efforts to integrate responsible and sustainable investing principles into its investment process. Certain examples are provided herein for illustrative purposes only and are not intended to be representative of Brandywine Global’s investment process with respect to every investment. ESG investments may be viewed as “sustainable, “responsible”, or “socially conscious” among other names. Analysis and integration of ESG factors is qualitative and subjective by nature, and there is no guarantee that the ESG criteria used, or judgment exercised, by Brandywine Global will reflect the values of any one particular investor. Different investment managers may utilize and evaluate ESG factors in different ways. Investing in ESG investments carries the risk that under certain market conditions, the investment strategy may underperform strategies that do not utilize a responsible investment strategy. An investment’s ESG performance or Brandywine Global’s assessment of such performance may change over time. ESG is not a uniformly defined characteristic and information used to evaluate ESG characteristics may not be readily available, complete, or accurate, and may vary across providers and issuers. The ESG considerations assessed as part of the research and investment approval process may vary across eligible investments and not every ESG factor may be evaluated for every investment. There is no guarantee that the evaluation of ESG characteristics will be additive to a strategy or account’s performance.

This website and the information contained herein does not constitute and is not intended to constitute an offer of any kind, including securities and accordingly should not be construed as such. Any products or services referenced on this website are for informational purposes only and may not be licensed or permitted to be purchased in your jurisdiction, and unless otherwise indicated, no regulator or government authority has reviewed this website or the merits of the products and services referenced. The content of this website is intended for eligible institutional investors (as such term is defined in any given jurisdiction). Before acting on any information on this website you should be well informed of and observe all applicable laws, rules and regulations of your home jurisdiction and obtain independent advice if required.

Past performance is no guarantee of future results.