Company Privacy & Disclosures

CRS Disclosure
Verdis Investment Management is a Registered Investment Advisor (RIA), as required by the family’s corporate Trustee.  Being an RIA allows Verdis to provide instruction as it relates to the family’s directed trusts held at the trust company.  As an RIA, we are required to share our Form CRS on our website, however it is worth noting that we do not provide wealth advisory services to external families/investors but rather only to one, single family. The form can be located at https://reports.adviserinfo.sec.gov/crs/crs_134445.pdf

Privacy Policy
At Verdis Investment Management we recognize the importance of maintaining the utmost security and confidentiality of our clients’ information. In addition to internal policies and procedures designed to safeguard client information, we prohibit those we do business with from any reuse of that information for purposes other than those intended by Verdis.

This privacy notice applies to all consumers who have a relationship with Verdis Investment Management, which is also referred to herein as “Verdis.” Verdis’ privacy notice is subject to change. For purposes of this notice, client information means personally identifiable information about a consumer who has a relationship with Verdis.

Accordingly, at Verdis we have adopted the following:

Client information security and confidentiality
We take a number of steps to ensure that client information is adequately safeguarded. These steps include the following: 1) implementing a number of physical and electronic security features to prevent unauthorized access; 2) limiting employee access to client information; and 3) conducting periodic reviews of our computer systems, including security features. Additionally, our employees are required to acknowledge their responsibility to maintain the confidentiality of client information.

How we collect client information
We collect client information that: 1) we receive on subscription documents to us for our products and/or services; 2) we receive from processing clients’ accounts with us and the transactions in those accounts, as well as providing services to our clients; 3) we receive about our clients from our affiliated companies; and 4) we receive in response to requests made to third parties about our clients or to confirm information that our clients have provided to us.

How we disclose client information
We may disclose some or all of the client information we collect about our clients under the following circumstances: 1) to verify or complete a transaction; 2) to verify the existence and condition of a client account for a third party, such as another financial institution; 3) to a third party who performs functions on behalf of Verdis (i.e. custodian, fund administrator); 4) to comply with laws, regulations, or a court or government order or request, such as in response to a subpoena or a request by an SEC/FINRA examiner; 5) to inform a client of our other products or services; 6) if a client or any authorized person on the account gives us oral or written permission to do so; or (7) to verify the accuracy of information that a client has provided to us.

We do not share your nonpublic information with other nonaffiliated third parties to market to you. As set forth above, we only share nonpublic information with third parties, as necessary to service your account(s) or as required by law. As such Verdis dues not allow the opting out of the disclosure of such information.

Client information shared among Verdis’ affiliates
Verdis has several affiliates that allow us to provide our clients with an array of financial services that include custody, trust, brokerage, and banking services. We may share some or all of the personal financial information we collect among our affiliates, except as limited herein. By sharing this information among our affiliates, we can serve our clients more efficiently and make it easier for them to do business with us. For example, if a client has an account with us and wants to open an account with one of our affiliated companies, we may share the information he or she provided to us.

Client information about former clients
We apply the same privacy polices and practices to our former clients that we do to our existing clients. Collected client information is retained in accordance with Federal law.

Client information – accuracy
We recognize the importance of maintaining accurate client information that is provided to our clients in various forms, including account statements and billing statements. If a client ever notices that his or her information is inaccurate, we ask they please contact us. Upon notification we will correct any inaccuracies.

Social Media Policy Disclosures & Terms of Use

Legal Terms of Use
Posts from Verdis Investment Management (Verdis) represent the opinions of Verdis and are not intended as investment advice or to predict or depict performance of any investment.  These views are as of the date they are posted and are subject to change based on subsequent developments.

The information on Verdis Investment Management’s LinkedIn page could pertain to U.S. residents only.  The information on this page or additional Verdis pages (or other content) on the LinkedIn platform does not constitute an offer to sell, or a solicitation of an offer to purchase, any services or investment products outside of the United States.

Commenting and Posting
As communication within our industry is highly regulated, please understand that while we value your opinion and contribution to the page, it may be necessary to remove comments or ports for a variety of reasons.

Any comments, posts or links to third party material posted by fans represents their opinion and not necessarily the view of Verdis.  Verdis is not responsible for and does not adopt or endorse any opinions, statements or links to third-party material posted by fans on the Verdis LinkedIn page, any other Social Media service page or content linked from third-party website.

LinkedIn is owned by a third-party unaffiliated with Verdis and as a user of the platform, it is important that users recognize their participation and usage is at their own risk.  For more information on LinkedIn’s privacy policy and terms of service, please visit:https://www.linkedin.com/legal/privacy-policy.

This privacy notice applies to all consumers who have a relationship with Verdis Investment Management, LLC, and Still Pond Capital, LLC (together, “we”, “us”, or the “Adviser”). The Adviser’s privacy notice is subject to change. For purposes of this notice, client information means personally identifiable information about a consumer who has a relationship with the Adviser.

We recognize the importance of maintaining the utmost security and confidentiality of our clients’ information. In addition to internal policies and procedures designed to safeguard client information, we prohibit those we do business with from any reuse of that information for purposes other than those intended by the Adviser.

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. The type of personal information we collect, and share depends on the product or service you have with us.

Accordingly, we have adopted the following:

Client information security and confidentiality

We take a number of steps to ensure that client information is adequately safeguarded. These steps include the following: 1) implementing a number of physical and electronic security features to prevent unauthorized access; 2) limiting employee access to client information; and

3) conducting periodic reviews of our computer systems, including security features. Additionally, our employees are required to acknowledge their responsibility to maintain the confidentiality of client information.

How we collect client information

We collect client information that: 1) we receive on subscription documents to us for our products and/or services; 2) we receive from processing clients’ accounts with us and the transactions in those accounts, as well as providing services to our clients; 3) we receive about our clients from our affiliated companies; and 4) we receive in response to requests made to third parties about our clients or to confirm information that our clients have provided to us.

How we disclose client information

We may disclose some or all of the client information we collect about our clients under the following circumstances: 1) to verify or complete a transaction; 2) to verify the existence and condition of a client account for a third party, such as another financial institution; 3) to a third party who performs functions on behalf of the Adviser (i.e. custodian, fund administrator); 4) to comply with laws, regulations, or a court or government order or request, such as in response to a subpoena or a request by an SEC/FINRA examiner; 5) to inform a client of our other products or services; 6) if a client or any authorized person on the account gives us oral or written permission to do so; or (7) to verify the accuracy of information that a client has provided to us.

We do not share your nonpublic information with other nonaffiliated third parties to market to you. As set forth above, we only share nonpublic information with third parties, as necessary to services your account(s) or as required by law. As such the Adviser does not allow the opting out of the disclosure of such information.

Please note:

If you are a new client, we can begin sharing your information 30 days from the days from the date we have sent this privacy notice. When you are no longer our client, we continue to share your information as described in this privacy notice.

Client information shared among Adviser affiliates

The Adviser has several affiliates that allow us to provide our clients with an array of financial services that include custody, trust, brokerage, and banking services. We may share some or all of the personal financial information we collect among our affiliates, except as limited herein. By sharing this information among our affiliates, we can serve our clients more efficiently and make it easier for them to do business with us. For example, if a client has an account with us and wants to open an account with one of our affiliated companies, we may share the information he or she provided to us.

What your rights are and how you can exercise them

In accordance with applicable regulations, you have the following rights:

• To access: you can obtain information relating to the processing of your personal data, and a copy of such personal data.
• To rectify: where you consider that your personal data are inaccurate or incomplete, you can require that such personal data be modified accordingly.
• To erase: you can require the deletion of your personal data.
• To restrict: you can request the restriction of the processing of your personal data.
• To object: you can object to the processing of your personal data, on grounds relating to your particular situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes profiling related to such direct marketing.
• To withdraw your consent: where you have given your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
• To data portability: where legally applicable, you have the right to have the personal data you have provided to us be returned to you or, where technically feasible, transferred to a third party.

If you wish to exercise one of the rights listed above, please contact us at info@verdisinvestment.com or by calling (610) 397-1600. In accordance with applicable regulation, in addition to your rights above, you are entitled to lodge an inquiry with the competent supervisory authority.

Client information about former clients

We apply the same privacy policy and practices to our former clients that we do to our existing clients. Collected client information is retained in accordance with Federal law.

Accuracy of client information

We recognize the importance of maintaining accurate client information that is provided to our clients in various forms, including account statements and billing statements. If a client ever notices that his or her information is inaccurate, we ask they please contact us. Upon notification we will correct any inaccuracies.

Incident response and privacy protections

We are committed to safeguarding client information in accordance with Regulation S-P under the Gramm-Leach-Bliley Act. In the event of a security incident involving unauthorized access to or use of sensitive personally identifiable information, the Adviser will promptly investigate the incident and, consistent with regulatory requirements, complete its assessment and provide notice to affected clients as soon as practicable, but no later than 30 days after becoming aware of the incident, unless a delay is permitted by law. Such notice will include, as applicable, a description of the incident, the types of information involved, and steps clients may take to protect themselves.

We also requires its third-party service providers to notify us of any actual or suspected security incident that is reasonably likely to have resulted in the unauthorized access to or exposure of such information as soon as possible, and in no event later than 72 hours after discovery. Upon receiving such notice, we will assess the scope and impact of the incident, take appropriate remedial measures to contain and mitigate any harm, coordinate with the service provider, and provide client notifications and any required regulatory filings or disclosures where warranted.