Privacy Policy

Yacktman Asset Management LP
Privacy Policy 2024

Our guiding principles

The relationship between Yacktman Asset Management LP (“Yacktman” or “we”) and its clients is our most important asset. We strive to maintain client (“you” or “your”) trust and confidence, 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.

Types of information we collect

Yacktman collects non-public personal information to provide investment management services. The types of information includes, but is not limited to:

• Information we receive from you, e.g., tax ID, address, occupation, financial information;
• Information that we generate to service your account, e.g., trading activity and account performance information;
• Information provided to us by third parties authorized to service your accounts, such as advisers, consultants, brokers, custodians; and
• Other information required for transacting business on your behalf.

Affiliated parties to whom we disclose information

Affiliated parties (“Affiliates”) are companies related by common ownership or control. We share information with affiliates as part of our normal financial reporting process.

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 nonaffiliated 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.

Type of information we disclose

We only disclose information necessary to transact business in client accounts or as necessary for audits and all other information as required by law. We do not sell our client information.

How we protect your client information

To fulfill our privacy commitment, 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.