Confidentiality

Confidentiality of Electronic Records:

OPM (in conjunction with any vendor) uses a password system to protect against unauthorized access to or use of customer records stored on electronic media. OPM changes passwords periodically and disables access for terminated Associated Persons and for anyone who no longer needs it.

Confidentiality of Client Account Information:

The Company has established safeguards to ensure that any confidential trading information of Clients is protected. All Client information will be considered confidential information and only limited access will be permitted. In addition, the Company maintains a separate Cybersecurity Policy. Please refer to that policy for additional information on information barriers. The Company maintains a separate Cybersecurity Policy. Please refer to that policy for security measures of internal data.

Confidentiality of Participant Accounts:

The Company has established safeguards to ensure that any confidential trading information of Participants is protected. All Participant information and orders will be considered confidential information and only limited access will be permitted. The Company maintains a separate Cybersecurity Policy. Please refer to that policy for security measures of internal data.