Common use of Other Financial Industry Activities and Affiliations Clause in Contracts

Other Financial Industry Activities and Affiliations. Confluence professionals from time to time assist other financial services organizations through providing advisory services for which they can be remunerated. These outside business activities are vetted by management prior to an employee’s involvement and routinely reviewed to ensure Confluence clients are not disadvantaged. Xxxx Xxxxxx, CEO and Chief Investment Officer of Confluence, is a member of the board of directors of Xxxxxxxx Xxxxxxx, Inc. (“BEI”), the holding company of Xxxxxxxx X. Xxxxxxx & Company (“BFEC”) and Xxxxxxx Wealth Management (“EWM”). Xx. Xxxxxx has a private investment in the equity securities of BEI. Although he has no day-to-day decision-making responsibilities for BEI, as a member of their board of directors he is involved in the development of strategy, policy and other important matters affecting the firm. Confluence offers its discretionary and non-discretionary investment advisory services to BFEC, EWM and their clients, as described above under Item 4 of this Brochure, titled Advisory Business. As part of Xx. Xxxxxx’x professional responsibilities with Confluence, he is involved in making investment decisions concerning portfolios of individual clients of BFEC and EWM. BFEC and EWM and their representatives do not receive any additional or different sales compensation in connection with recommendations to clients concerning Confluence versus any Financial Institution in comparable circumstances. Confluence and Xx. Xxxxxx do not receive any additional compensation in connection with client investments placed with Confluence through BFEC and EWM due to Xx. Xxxxxx’x position on the board. Xx. Xxxxxx is compensated for his service as a board member of BEI on the same terms as other independent board members. Xxxxx Xxxxxx, President and Chief Operating Officer of Confluence, is the sole owner of Xxxxxx Investment Partners LLC (“HIP”). HIP provides non-investment advisory services to corporate clients for which it receives fixed fees. HIP and Confluence have a mutual client: First Trust Portfolios L.P. (“First Trust”), a Financial Institution for which Confluence provides discretionary portfolio management and investment advisory services by acting as a sub-advisor to an open- end mutual fund and a closed-end fund for which an affiliate of First Trust serves as investment adviser. Additionally, the Confluence Growth and Income Alpha Strategy includes allocations to certain First Trust sponsored ETFs. Confluence may from time to time provide services to First Trust in connection with the creation and supervision of unit investment trust portfolios sponsored by First Trust. On November 1, 2012, Xxxxx Xxxxxx joined the board of directors of Franklin Street Properties Corp (NYSE: FSP), a publicly traded Real Estate Investment Trust. Xx. Xxxxxx has personal, long-term investments in securities issued by FSP and expects to make additional investments in FSP for his own account from time to time. Confluence evaluates each investment idea on its own merits and has established policies and procedures that address conflicts of interest that are or may be raised by Xx. Xxxxxx’x relationship with FSP. Xx. Xxxxxx does not provide Confluence or Confluence’s Value Equities Investment Committee with information relating to FSP. Xx. Xxxxxx’x transactions in FSP securities must be affected in accordance with Confluence’s policies and procedures relating to personal securities transactions as well as in accordance with applicable legal requirements.

Other Financial Industry Activities and Affiliations. Confluence professionals from time to time assist other financial services organizations through providing advisory services for which they can be remunerated. These outside business activities are vetted by management prior to an employee’s involvement and are routinely reviewed to ensure Confluence clients are not disadvantaged. Xxxx Xxxxxx, CEO and Chief Investment Officer of Confluence, is a member of the board of directors of Xxxxxxxx Xxxxxxx, Inc. (“BEI”), the holding company of Xxxxxxxx X. Xxxxxxx & Company (“BFEC”) and Xxxxxxx Wealth Management (“EWM”). Xx. Xxxxxx has a private investment in the equity securities of BEI. Although he has no day-to-day decision-making responsibilities for BEI, as a member of their board of directors he is involved in the development of strategy, policy policy, and other important matters affecting the firm. Confluence offers its discretionary and non-discretionary investment advisory services to BFEC, EWM EWM, and their clients, as described above under Item 4 of this Brochure, titled Advisory Business. As part of Xx. Xxxxxx’x professional responsibilities with Confluence, he is involved in making investment decisions concerning portfolios of individual clients of BFEC and EWM. BFEC and EWM and their representatives do not receive any additional or different sales compensation in connection with recommendations to clients concerning Confluence versus any Financial Institution in comparable circumstances. Confluence and Xx. Xxxxxx do not receive any additional compensation in connection with client investments placed with Confluence through BFEC and EWM due to Xx. Xxxxxx’x position on the board. Xx. Xxxxxx is compensated for his service as a board member of BEI on the same terms as other independent board members. Xxxxx Xxxxxx, President and Chief Operating Officer of Confluence, is the sole owner of Xxxxxx Investment Partners LLC (“HIP”). HIP provides non-investment advisory services to corporate clients for which it receives fixed fees. HIP and Confluence have a mutual client: First Trust Portfolios L.P. (“First Trust”), a Financial Institution for which Confluence provides discretionary portfolio management and investment advisory services by acting as a sub-advisor to an open- end mutual fund and a closed-end fund for which an affiliate of First Trust serves as investment adviser. Additionally, the Confluence Growth and & Income Alpha Strategy strategy includes allocations to certain First Trust Trust-sponsored ETFs. Confluence may will from time to time provide services to First Trust in connection with the creation and supervision of unit investment trust portfolios sponsored by First Trust. On November 1, 2012, Xxxxx Xxxxxx joined the board of directors of Franklin Street Properties Corp (NYSE: FSP), a publicly traded Real Estate Investment Trust. Xx. Xxxxxx has personal, long-term investments in securities issued by FSP and expects to make additional investments in FSP for his own account from time to time. Confluence evaluates each investment idea on its own merits and has established policies and procedures that address conflicts of interest that are or may be raised by Xx. Xxxxxx’x relationship with FSP. Xx. Xxxxxx does not provide Confluence or Confluence’s Value Equities Investment Committee with information relating to FSP. Xx. Xxxxxx’x transactions in FSP securities must be affected in accordance with Confluence’s policies and procedures relating to personal securities transactions as well as in accordance with applicable legal requirements.

Other Financial Industry Activities and Affiliations. Confluence professionals from time to time assist other financial services organizations through providing advisory services for which they can be remunerated. These outside business activities are vetted by management prior to an employee’s involvement and are routinely reviewed to ensure Confluence clients are not disadvantaged. Xxxx Xxxxxx, CEO and Chief Investment Officer of Confluence, is a member of the board of directors of Xxxxxxxx Xxxxxxx, Inc. (“BEI”), the holding company of Xxxxxxxx X. Xxxxxxx & Company (“BFEC”) and Xxxxxxx Wealth Management (“EWM”). Xx. Xxxxxx has a private investment in the equity securities of BEI. Although he has no day-to-day decision-making responsibilities for BEI, as a member of their board of directors he is involved in the development of strategy, policy and other important matters affecting the firm. Confluence offers its discretionary and non-discretionary investment advisory services to BFEC, EWM and their clients, as described above under Item 4 of this Brochure, titled Advisory Business. As part of Xx. Xxxxxx’x professional responsibilities with Confluence, he is involved in making investment decisions concerning portfolios of individual clients of BFEC and EWM. BFEC and EWM and their representatives do not receive any additional or different sales compensation in connection with recommendations to clients concerning Confluence versus any Financial Institution in comparable circumstances. Confluence and Xx. Xxxxxx do not receive any additional compensation in connection with client investments placed with Confluence through BFEC and EWM due to Xx. Xxxxxx’x position on the board. Xx. Xxxxxx is compensated for his service as a board member of BEI on the same terms as other independent board members. Xxxxx Xxxxxx, President and Chief Operating Officer of Confluence, is the sole owner of Xxxxxx Investment Partners LLC (“HIP”). HIP provides non-investment advisory services to corporate clients for which it receives fixed fees. HIP and Confluence have a mutual client: First Trust Portfolios L.P. (“First Trust”), a Financial Institution for which Confluence provides discretionary portfolio management and investment advisory services by acting as a sub-advisor to an open- end mutual fund and a closed-end fund for which an affiliate of First Trust serves as investment adviser. Additionally, the Confluence Growth and Income Alpha Strategy includes allocations to certain First Trust sponsored ETFs. Confluence may will from time to time provide services to First Trust in connection with the creation and supervision of unit investment trust portfolios sponsored by First Trust. On November 1, 2012, Xxxxx Xxxxxx joined the board of directors of Franklin Street Properties Corp (NYSE: FSP), a publicly traded Real Estate Investment Trust. Xx. Xxxxxx has personal, long-term investments in securities issued by FSP and expects to make additional investments in FSP for his own account from time to time. Confluence evaluates each investment idea on its own merits and has established policies and procedures that address conflicts of interest that are or may be raised by Xx. Xxxxxx’x relationship with FSP. Xx. Xxxxxx does not provide Confluence or Confluence’s Value Equities Investment Committee with information relating to FSP. Xx. Xxxxxx’x transactions in FSP securities must be affected effected in accordance with Confluence’s policies and procedures relating to personal securities transactions as well as in accordance with applicable legal requirements.