Social Media Policy
Personal Social Media:
a. Usage Standard – Personal use of social media by the Firm’s personnel must be legal and ethical.
b. Attribution
i. Personal use of social media by the Firm’s personnel must not create an impression that an employee is speaking for the Firm.
ii. Personnel are limited to referencing the Firm when accurately listing their current and historical employment status or company affiliation on LinkedIn or other sites for purposes of identification. Employees are otherwise prohibited from referencing the Firm on social media.
c. Limitations
i. Personnel must not use their personal social media accounts to disclose material nonpublic information about the Firm; confidential information belonging to the Firm; or any confidential third-party information held by the Firm.
ii. Personnel may not mention the Firm’s product(s) or service(s) or their performance in personal social media communications.
iii. Firm personnel must not engage in discussion of individual securities or the Firm’s products or services in social media.
iv. As the maintenance of the Firm’s corporate reputations is essential to the successful operations of the Firm, all personnel are cautioned that any content posted to their personal social media accounts that could reflect negatively on the individual’s role at the Firm or the Firm themselves may be deemed grounds for disciplinary or other remedial actions by the Firm. Accordingly, all personnel are strongly encouraged to refrain from posting, communicating or otherwise interacting with any content that may be deemed offensive or otherwise distasteful.
d. Attestation and Monitoring
i. Employees shall identify any personal social media service identities or profiles identified by the CCO as requiring proactive monitoring and provide timely updates to the CCO of any additions or revisions to such monitored identities or profiles that could reasonably be expected to impact monitoring.
ii. Employees shall attest to their compliance with these requirements applicable to the use of personal social media as requested by the CCO.
Company Social Media:
Summit Global Investments, LLC maintains profiles and/or pages on social media sites LinkedIn and Twitter. If you choose to “Follow” Summit Global Investments, LLC on LinkedIn or Twitter and take any similar action on another social media site, you are providing your consent to receive information updates, including solicitations, from Summit Global Investments, LLC. To stop receiving this information from Summit Global Investments, LLC on a social media site, you must follow the procedure established by the site.
The information contained in Summit Global Investments social media profiles and pages is current as of the date of publication (or such earlier date as referenced) and is subject to change without notice. Summit Global Investments, LLC has no obligation to update any or all of such information. Additionally, Summit Global Investments personnel other than the author(s) may provide oral or written market commentary or investment ideas to Summit Global Investments, LLC clients or prospects that differ from the views expressed. Summit Global Investments, LLC may make investment decisions that are inconsistent with the recommendations or views expressed within social media sites.
All amounts, market value information, and estimates have been obtained from outside sources where indicated or represent the good faith judgment of Summit Global Investments, LLC. Where such information has been obtained from outside sources, Summit Global Investments, LLC cannot guarantee its accuracy or completeness. Past performance is not a guarantee or reliable indicator of future results.
Summit Global Investments, LLC social media profiles and pages are not intended to be an offer or solicitation with respect to the purchase or sale of any security or other financial instrument or any investment management services. They are provided for information purposes only, do not constitute investment advice, and should not be used as the basis for any investment decision. They also do not purport to provide any legal, tax, or accounting advice.
LinkedIn and Twitter are unaffiliated with Summit Global Investments, LLC. Summit Global Investments, LLC is not responsible for the terms of use or policies of any of the social media sites on which it maintains a profile or page or any third-party sites to which they are linked, and you use these sites at your own risk. Summit Global Investments, LLC is not responsible for and does not endorse any content, advertising, products, advice, opinions, recommendations, terms of use or privacy policies, or other materials on or available from third parties.
While Summit Global Investments, LLC may monitor postings by third parties on its profiles and pages, Summit Global Investments, LLC is not able to review them before they are displayed, and any such postings are the views and responsibilities of the posters. Summit Global Investments, LLC does reserve the right to edit or remove any post for any reason and to block followers to the extent permitted by the sites. If Summit Global Investments, LLC does not remove a third-party post, it is not an endorsement of the content.
Summit Global Investments, LLC does not provide customer service, conduct financial transactions, or accept customer complaints through its social media profiles and/or pages. Never disclose account or other personal financial information on any of our social media profiles or pages.
Investing in funds involve risk, and you can lose money.
You should carefully consider a fund’s investment goals, risks, charges and expenses before investing. This and other important information is contained in the fund’s prospectus. To obtain a prospectus, visit www.sgaim.com or contact your investment professional or call (888) 251-4847. Please carefully read the prospectus before you invest or send money.
