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Privacy Policy

Our guiding principles
The relationship between Yacktman Asset Management LP ("Yacktman") and our clients is the most important asset of our firm. We strive to maintain your trust and confidence in our firm, an essential part of which is our commitment to protecting your privacy. Accordingly, keeping our clients' non‐public personal information confidential is our top priority. As such, we do not share or disclose any non‐public personal information about our clients or former clients to non-affiliated third parties, unless required by law, at your direction, or as necessary to provide services to you, as described below.

Type of information we collect
Yacktman Asset Management LP collects non-public personal information to provide investment management services to you. The type of information includes, but is not limited to:

  • Information we receive from you to open an account or provide investment advice to you, e.g., name, addresses, phone numbers, financial information;
  • Information that we generate to service your account, e.g., trading activity and performance information;
  • Information provided to us by third parties authorized to service your accounts, such as attorneys, consultants, and brokers; and
  • Other information required for transacting business on your behalf.

Affiliates to whom we disclose information
Affiliates are companies related by common ownership or control. We share information with certain affiliates as part of our normal financial reporting processes, as necessary to transact business on your behalf and when necessary to assist us in communicating on your behalf.

Non-affiliated parties to whom we disclose information
Non-affiliated parties are companies not related by common ownership or control. We will disclose client information to non-affiliated service providers when necessary to transact business on your behalf or when necessary to assist us in communicating on your behalf. Such organizations might include your legal, banking, or accounting representatives (when authorized by you), our auditors, our legal counsel, and proxy voting agent. We do not disclose information about our former clients (other than to the parties described above and for purposes listed above).

Type of information we disclose
We only disclose information as necessary to transact business in customer accounts. In addition, we must provide information necessary for audits and all other information as required by law. Client references may be disclosed, but only with your prior approval. We do not sell our client information.

How we protect your client information
To fulfill our privacy commitment at Yacktman Asset Management, we have implemented physical, electronic, and procedural safeguards to protect the information we maintain about you. These include:

  • Limiting access to electronic information by electronic safeguards, such as passwords for access to our networks and computers;
  • Limiting access to personal information to those employees who need it to perform their job duties; and
  • Requiring third parties that will perform services involving client information to agree to keep your information strictly confidential.

March 2016