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Terms of Use and Policies

1. Acceptance of the Terms and Conditions

1.1 Silvercrest Asset Management Group LLC (herein referred to as the “Company,” “we,” “us” or “our”) provides and makes available this web site (the “Web Site”). All use of this Web Site is subject to the terms and conditions contained in this Terms of Use Agreement (the “Agreement”). By accessing, browsing or using this Web Site, you acknowledge that you have read, understood, and agree to be bound by this Agreement. If you do not accept the terms and conditions of this Agreement, do not access, browse or use the Web Site.

1.2 You understand and agree that we may change this Agreement at any time without prior notice. You may read a current, effective copy of this Agreement at any time by selecting the “Terms of Use” link on the Web Site. If any change to this Agreement is not acceptable to you, your sole remedy is to cease accessing, browsing and using the Web Site. Any use of the Web Site after changes are made to the Agreement shall constitute your acceptance of such revised terms and conditions.

2. Use of the Web Site.

2.1 This Web Site contains material, including but not limited to works of original authorship, software, text, graphics and images (collectively referred to as the “Content”). We may own the Content. Portions of the Content may be made available to us for distribution through arrangements that we have with third parties. The Content is protected by copyright under both United States and foreign laws. Unauthorized use of the Content may result in violation of copyright, trademark, and other laws. Except as to information regarding your securities and positions, you agree not to use the Content except as permitted under this Agreement. No other use is permitted without prior written consent from us. Clients of Silvercrest may print copies of pages on our site for their own lawful, personal, non-commercial use. In so doing, they must retain all copyright and other proprietary notices contained in the original Content. You may not sell, transfer, assign, license, sublicense, or modify the Content or reproduce, display, publicly perform, make a derivative version of, distribute, or otherwise use the Content in any way for any public or commercial purpose. The use or posting of the Content on any other web site or in a networked computer environment for any purpose is expressly prohibited.

2.2 The trademarks, service marks, and logos of the Company (the “Company Trademarks”) used and displayed on this Web Site are registered and unregistered trademarks or service marks of the Company. Other company, product, and service names located on the Web Site may be trademarks or service marks owned by third parties (the “Third-Party Trademarks”, and, collectively with the Company Trademarks, the “Trademarks”). Nothing on this Web Site should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any Trademark displayed on this Web Site without the prior written consent of the Company specific for each such use. The Trademarks may not be used to disparage the Company or the applicable third-party, the Company’s or third-party’s products or services, or in any manner (using commercially reasonable judgment) that may damage any goodwill in the Trademarks. Use of any Trademarks as part of a link to or from any site is prohibited unless the Company, in advance, in writing, approves the establishment of such a link. All goodwill generated from the use of any Company Trademark shall inure to the Company’s benefit.

2.3 No user of this Web Site may (a) take any action that imposes an unreasonable load on the Web Site’s infrastructure, (b) use any device, software or routine to interfere or attempt to interfere with the proper working of the Web Site or any activity being conducted on the Web Site, (c) attempt to decipher, decompile, disassemble or reverse engineer any of the software comprising or making up the Web Site, (4) delete or alter any material posted by any other person or entity, or (5) frame or link to any of the materials or information available from the Web Site.

2.4 The Web Site may contain links to third party web sites (“External Sites”). These links are provided solely as a convenience to you and not as an endorsement by us of the content on such External Sites. The content of such External Sites is developed and provided by others. You should contact the site administrator or Webmaster for those External Sites if you have any concerns regarding such links or any content located on such External Sites.

We are not responsible for the content of any linked External Sites and do not make any representations regarding the content or accuracy of materials on such External Sites. You should take precautions when downloading files from all web sites to protect your computer from viruses and other destructive programs. If you decide to access linked External Sites, you do so at your own risk.

3. Limit of Liability and Warranty.

3.1 THE COMPANY, ITS AFFILIATES, THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, SUPPLIERS, OR LICENSORS (COLLECTIVELY, THE “COMPANY PARTIES“) MAKE NO WARRANTIES OR REPRESENTATIONS ABOUT THE CONTENT, INCLUDING BUT NOT LIMITED TO ITS ACCURACY, RELIABILITY, COMPLETENESS, TIMELINESS, OR RELIABILITY. THE COMPANY PARTIES SHALL NOT BE SUBJECT TO LIABILITY FOR TRUTH, ACCURACY, OR COMPLETENESS OF ANY INFORMATION CONVEYED TO THE USER OR FOR ERRORS, MISTAKES OR OMISSIONS THEREIN OR FOR ANY DELAYS OR INTERRUPTIONS OF THE DATA OR INFORMATION STREAM FROM WHATEVER CAUSE. YOU AGREE THAT YOU USE THE WEB SITE AND THE CONTENT AT YOUR OWN RISK. THE COMPANY PARTIES DO NOT WARRANT THAT THE WEB SITE WILL OPERATE ERROR-FREE OR THAT THIS WEB SITE, ITS SERVER, OR THE CONTENT ARE FREE OF COMPUTER VIRUSES OR SIMILAR CONTAMINATION OR DESTRUCTIVE FEATURES. IF YOUR USE OF THE WEB SITE OR THE CONTENT RESULTS IN THE NEED FOR SERVICING OR REPLACING EQUIPMENT OR DATA, NO COMPANY PARTY SHALL BE RESPONSIBLE FOR THOSE COSTS. THE WEB SITE AND CONTENT ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS WITHOUT ANY WARRANTIES OF ANY KIND. THE COMPANY PARTIES DISCLAIM ALL WARRANTIES, INCLUDING, BUT NOT LIMITED TO, THE WARRANTY OF TITLE, MERCHANTABILITY, NON-INFRINGEMENT OF THIRD PARTIES’ RIGHTS, AND FITNESS FOR PARTICULAR PURPOSE.

3.2 IN NO EVENT SHALL ANY COMPANY PARTY BE LIABLE FOR ANY DAMAGES WHATSOEVER (INCLUDING, WITHOUT LIMITATION, INCIDENTAL AND CONSEQUENTIAL DAMAGES, LOST PROFITS, OR DAMAGES RESULTING FROM LOST DATA OR BUSINESS INTERRUPTION) RESULTING FROM THE USE OR INABILITY TO USE THE WEB SITE AND THE CONTENT, WHETHER BASED ON WARRANTY, CONTRACT, TORT (INCLUDING NEGLIGENCE), OR ANY OTHER LEGAL THEORY, EVEN IF A COMPANY PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

3.3 Some states do not allow exclusion of implied warranties or limitation of liability for incidental or consequential damages, so the above limitations or exclusions may not apply to you. IN SUCH STATES, THE LIABILITY OF THE COMPANY PARTIES SHALL BE LIMITED TO THE GREATEST EXTENT PERMITTED BY LAW.

4. Indemnification. You agree to defend, indemnify, and hold harmless the Company, from and against any claims, actions or demands, including, without limitation, reasonable legal and accounting fees, arising or resulting from your breach of this Agreement or your access to, use or misuse of the Content or Web Site. The Company shall provide notice to you of any such claim, suit, or proceeding and shall assist you, at your expense, in defending any such claim, suit or proceeding. The Company reserves the right to assume the exclusive defense and control of any matter which is subject to indemnification under this section. In such case, you agree to cooperate with any reasonable requests assisting the Company’s defense of such matter.

5. Termination of the Agreement.

5.1 Termination. The Company reserves the right, in its sole discretion, to restrict, suspend, or terminate this Agreement and your access to all or any part of the Web Site or the Content, at any time and for any reason without prior notice or liability. The Company reserves the right to change, suspend, or discontinue all or any part of the Web Site or the Content at any time without prior notice or liability.

5.2 Survival. If this Agreement is terminated, Sections 2 (Use of the Web Site), 3 (Limit of Liability and Warranty), 4 (Indemnification), 5 (Termination of Agreement), 6 (No Framing), and 9 (Miscellaneous) shall survive the termination of this Agreement.

6. No Framing. Elements of the Web Site are protected by trade dress, trademark, unfair competition, and other state and federal laws and may not be copied or imitated in whole or in part, by any means, including but not limited to, the use of framing or mirrors, except where allowed in Section 2. None of the Content for this Web Site may be retransmitted without express written consent from the Company for each and every instance.

7. User Must Comply with Applicable Laws.

7.1 This Web Site is based in and operated out of the State of New York. We make no claims concerning whether the Content may be downloaded, viewed, or be appropriate for use outside of the United States. If you access the Web Site or the Content from outside of the United States, you do so at your own risk. Whether inside or outside of the United States, you are solely responsible for ensuring compliance with the laws of your specific jurisdiction.

7.2 The United States controls the export of products and information. You expressly agree to comply with such restrictions and not to export or re-export any of the Content to countries or persons prohibited under the export control laws. By downloading the Content, you are expressly agreeing that you are not in a country where such export is prohibited or are a person or entity for which such export is prohibited. You are solely responsible for compliance with the laws of your specific jurisdiction regarding the import, export, or re-export of the Content.

8. Information for Foreign Investors.  Nothing on this website shall be considered a solicitation to buy or an offer to sell a security, or any other product or service, to any person in any jurisdiction where such solicitation, offer, purchase or sale would be unlawful under the laws of such jurisdiction.

9. U.S. Government Restricted Rights. The Content is provided with “RESTRICTED RIGHTS.” Use, duplication, or disclosure by the Government is subject to the restrictions contained in 48 CFR 52.227-19 and 48 CFR 252.227-7013 et seq. or its successor. Use of the Web Site or Content by the Government constitutes acknowledgement of our proprietary rights in the Web Site and Content.

10. Miscellaneous.

10.1 This Agreement is governed by the internal substantive laws of the State of New York, without respect to its conflict of laws provisions. You expressly agree to submit to the exclusive personal jurisdiction of the United States District Court for the Southern District of New York.

10.2 If any provision of this Agreement is found to be invalid by any court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Agreement, which shall remain in full force and effect.

9.3 Failure of the Company to act on or enforce any provision of the Agreement shall not be construed as a waiver of that provision or any other provision in this Agreement. No waiver shall be effective against the Company unless made in writing, and no such waiver shall be construed as a waiver in any other or subsequent instance.

10.4 Except as expressly agreed by the Company and you, this Agreement constitutes the entire Agreement between you and the Company with respect to the subject matter, and supercedes all previous or contemporaneous agreements, whether written or oral, between the parties with respect to the subject matter.

10.5 The section headings are provided merely for convenience and shall not be given any legal import.

10.6 This Agreement will inure to the benefit of our successors, assigns, licensees, and sublicensees.

10.7 Any information submitted or provided by you to the Web Site might be publicly accessible. Important and private information should be protected by you. The Company is not liable for protection of privacy of electronic mail or other information transferred through the Internet or any other network that you may use.

Your Privacy is Important to Us

At Silvercrest, we understand that our relationship with you is based on trust. This is reflected in everything we do, including the way we handle our clients’ nonpublic personal information. The following disclosure explains what personal information we collect, what we do with that information and the steps we have put in place to protect the nonpublic personal information you have entrusted to us.

If you have received a separate client privacy notice from us, as listed below, please refer to that notice for information on how we will collect and process your personal data for the provision of our products or services.

Information We Collect

From time to time, we gain access to your personal information through:

  • Our interaction with you on the telephone, in person or through e-mail
  • Account Applications or other forms you complete
  • Transactions in your accounts or on your behalf
  • Our website or the websites of our affiliated companies
  • Trading tools or other information tools we may make available to you
  • Third parties with whom we deal

The categories of personal information that we collect and process in order to provide our products and services include:

  • Personal details (e.g. name, date of birth, passport information, identification information, tax id number, biographical information)
  • Contact details (e.g. phone number, email address, postal address, mobile number)
  • Client-related details (e.g. relationship with the client or related parties, business information, information about any shareholdings, business contact details)

Transactional details (e.g. client account information as well as information about services, requests, queries or complaints). It is the policy of Silvercrest, in collecting personal information in the course of business to:

  • Protect the confidentiality of your personal information;
  • Prohibit the unlawful disclosure of your personal information; and
  • Limit access to such personal information

What We Use Personal Information For

Personal information is used to manage the relationship with our clients, to comply with a legal obligation, and/or because we have a legitimate interest. This will include the following:

  • For research and statistical analysis with the aim of improving our services;
  • To validate authorized signatories when concluding agreements and transactions;
  • To contact individuals in connection with existing transactions and contractual agreements;
  • For risk management, for fraud detection and prevention, including know your customer, anti- money laundering, due diligence requirements, credit checks, compliance with sanction rules, fraud monitoring, and tax reporting;
  • To comply with laws and regulations (including any legal or regulatory guidance, codes or opinions);
  • To send administrative information to you, such as changes to our terms, conditions and

Information We Disclose

It is Silvercrest policy not to disclose any of your nonpublic personal information to third parties without your consent, unless those parties are providing services or support to us and have agreed to keep your nonpublic personal information confidential. Examples of these parties include the custodians with which you have entrusted your assets, our attorneys and the firm(s) that perform our internal auditing. Even if you cease to transact business with Silvercrest, we will continue to apply the same protections to your nonpublic personal information as we did when you were an active client.

The Silvercrest Family of Companies

Silvercrest Asset Management Group LLC is at the center of a small family of related companies which are owned in whole or in part by Silvercrest L.P. These affiliated companies allow us to provide greater value to our customers, employees and shareholders. In the course of our business, employees or representatives of various Silvercrest affiliates will have access to your nonpublic personal information. They have agreed to hold your information confidential and to comply with the privacy policy established by Silvercrest.

Protecting Your Information

Silvercrest protects your nonpublic information from access by third parties by maintaining physical, electronic and procedural safeguards. We limit access to your information to those employees who are trained in the proper handling of nonpublic client information and who need access to the information to perform their job functions. We do not share your information for marketing purposes.

Federal law gives you the right to limit some but not all disclosure (or sharing) of your information. State laws may give you additional rights to limit sharing. You can limit our sharing information: (i) about your creditworthiness with our affiliates; and (ii) with anyone for marketing purposes.

For more information, to find out what personal information of yours we have collected, or to update your personal information, please contact the Office of the General Counsel at Silvercrest at 212-649-0623.

For separate client privacy notices received from us, please refer to these, as applicable:
Silvercrest European Investor Privacy Policy Notice
Silvercrest Cayman Funds – Cayman DPL Notice
Silvercrest California Residents Privacy Policy

Employees of Silvercrest always have a responsibility to treat others with dignity and respect, in keeping with the firm’s principles. All employees are expected to exhibit conduct that reflects respect for and collegiality toward each individual during work, at work functions in or out of the office, and at all other company-sponsored events.

Silvercrest Asset Management Group embraces and cultivates a culture of diverse ideas and backgrounds. Our employees are the most important assets at the firm. Their individual differences, life experiences, knowledge, inventiveness, innovation, self-expression, unique capabilities and talent makes us a better firm. We are committed to an inclusive work environment and value our employees’ differences in age, color, disability, ethnicity, family or marital status, gender identity or expression, language, national origin, physical and mental ability, political affiliation, race, religion, sexual orientation, socio-economic status, veteran status, and other characteristics.

We seek to attract talent from the broadest candidate pools possible. Our commitment to diversity affects our practices and policies with respect to recruitment and hiring; compensation and benefits; professional development and training; promotions; transfers; social and recreational programs; layoffs; and terminations. We seek a work environment that encourages and enforces:

  • Respectful communication and cooperation between all employees;
  • Teamwork and employee participation, permitting the representation of all groups and employee perspectives;
  • Work/life balance through flexible work schedules to accommodate employees’ varying needs.
  • Employer and employee contributions to and involvement in the communities we serve.

Introduction

Since our 2002 inception, Silvercrest Asset Management Group has sought to deliver an unparalleled level of high-quality advice and attractive investment results for our clients. In addition to our modern approach to portfolio construction and institutional-quality research and security selection capabilities, we offer a high level of personalized service and client communication resulting in a 98% client retention rate since our inception.

Quality, risk management, and preservation of client capital is the hallmark of Silvercrest’s investment approach. Intensive fundamental financial research and securities analysis underpins our approach to individual security selection within the variety of proprietary investment strategies we offer institutional and family clients.

Investment Strategies

Silvercrest offers the following propriety investment strategies to investors:

U.S. Value Equity Management

  • U.S. Large Cap Value
  • U.S. Equity Income
  • U.S. Multi Cap Value
  • U.S. SMID Cap Value
  • U.S. Small Cap Value
  • U.S. Focused Value

U.S. Growth Equity Management

  • U.S. Large Cap Growth
  • U.S. Multi Cap Growth
  • U.S. SMID Growth
  • U.S. Small Cap Growth
  • U.S. Small Cap Opportunity

International Value Equity Management

  • Global Value
  • International Multi Cap Value
  • Focused International Value
  • International Small Cap Value
  • Emerging Markets ADR

Environmental, Social and Governance Factors (ESG)

Silvercrest takes a holistic values approach toward managing client assets. This includes avoiding certain sectors and industries for social reasons, and the implementation of codified Socially Restricted Investment (SRI) screens based on client-specific investment policies and guidelines. These SRI screens have included a variety of investment areas over time.  More recently, some clients have become focused on the effect of environmental, social, and governance (“ESG”) factors on investments, and how these factors may be integrated in our investments on their behalf. We endeavor to meet these client criteria, as we do all client preferences.

As regulations and rules regarding ESG disclosures expand and more companies provide information on ESG factors, Silvercrest’s various investment teams seek to integrate that information.  Should we have ESG concerns when researching a potential investment, or with an existing invested company, we address them in the same manner that we address business strategy, capital allocation, executive compensation, or other concerns.

ESG Investment Philosophy

As with all other company metrics we analyze, Silvercrest evaluates environmental and social issues through the lens of generating long-term shareholder value. We believe companies should consider material environmental and social risks to their operations, and companies should provide disclosures that allow investors to understand how these factors are being considered and the attendant risks mitigated.

Executive Compensation

Silvercrest monitors companies’ performance with respect to environmental and social issues, including those related to climate and human capital management. Although we support companies’ incorporation of material E&S risks and opportunities in their long-term strategic planning, we believe the inclusion of E&S metrics in compensation programs should be predicated on each company’s unique circumstances. To establish a meaningful link between pay and performance, companies must consider factors including their industry, size, risk profile, maturity, performance, financial condition, and other relevant internal or external factors.

Engagement

Meetings with company management teams of prospective or current investments have always been an important part of our investment process. Our investment teams meet regularly with company management teams, along with additional conference calls, meetings, or emails, or as part of joint communications with the investment community. As more companies provide detailed information on ESG factors, our teams analyze those disclosures and engage with management to better understand those issues, including management’s efforts to solve or manage the risks of ESG factors that are prevalent in their industry and business.  Silvercrest has kept our proprietary research and engagement efforts private and for the exclusive benefit of our clients. If we disagree with management’s policies, procedures, governance, or business strategy we generally choose not to invest in a prospective holding, or we will trim or sell an existing investment in favor of opportunities where we have a higher level of confidence in the outcome.

Proxy Voting

Proxy voting is an important component in the ongoing dialogue with the companies in which we invest and view it as enhancing long-term value. As a policy, SIlvercrest votes on all shares held where practicable. Our voting decisions are informed by corporate governance Codes and best practices, external governance research and advice, as well as research by Silvercrest’s investment teams.

This link leads to the machine-readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.

 

https://www.cigna.com/legal/compliance/machine-readable-files

Silvercrest Asset Management Group LLC (“Silvercrest”) offers employment without regard to race, creed, color, national origin, sex, age, mental or physical disability, marital status, sexual orientation or preference, citizenship status, ancestry, ethnic heritage, military or veteran’s status or any other protected group or status in accordance with California, New York, New York City, and U.S. federal laws. Silvercrest is dedicated to ensuring fulfillment of this policy with regards to recruitment, hiring, compensation, benefits, placement, selection for training, promotion, transfer, demotion, layoff, termination, and general treatment during employment.

 We will do this by:

  • Seeking to attract talent from the broadest candidate pools possible.
  • Education and training programs for employees.
  • A complaint process that will promptly address any perceived discrimination that violates our policy, and other non-discrimination laws.

Silvercrest embraces and cultivates a culture of diverse ideas and backgrounds. Our employees are the most important assets at the firm. Their individual differences, life experiences, knowledge, inventiveness, innovation, self-expression, unique capabilities, and talent makes us a better firm. We are committed to an inclusive work environment and value our employees’ differences in age, color, disability, ethnicity, family or marital status, gender identity or expression, language, national origin, physical and mental ability, political affiliation, race, religion, sexual orientation, socio-economic status, veteran status, and other characteristics.

If you have concerns or complaints about any type of discrimination in the workplace you must bring these issues directly to the attention of the General Counsel or the Equal Employment Opportunity Officer. Silvercrest does not authorize or condone unlawful discrimination or retaliation. In addition, if you feel you have been the subject of sexual harassment or any other form of workplace harassment, please refer to the separate policy prohibiting sexual harassment and other forms of workplace harassment.