Proxy Policy

Amberwave’s Proxy Voting Policies are not meant to be exhaustive, nor can they anticipate every potential issue on which shareholders may be asked to vote. Amberwave believes in encouraging corporations to adopt policies that result in long-term value creation for shareholders and for society, including by fostering jobs, security and growth for the United States. Proxy voting is one tool that Amberwave uses to communicate these values to management teams in order to influence corporate behavior for the benefit of all Americans.

In accordance with the above general voting policy, Amberwave will generally adhere to the voting policies below.

Jobs. Amberwave believes economic opportunity is fundamental to improving the lives of all Americans across all American communities. Amberwave therefore votes to support corporate policies that it believes will create additional opportunity in the labor market, including by providing high quality jobs for economically disadvantaged constituencies. Amberwave also votes to oppose policies that it believes are designed to generate corporate profits by substituting American jobs for cheaper foreign labor.

Security. Amberwave believes that the long-term well-being and prosperity of the American people is inextricably linked to the security of the United States. Amberwave therefore votes to support corporate policies that it believes increase the resilience of the United States against exogenous shocks, including pandemics and natural disasters, and against hostile actions from strategic competitors to the United States who seek to use economic and corporate action to weaken the United States. Amberwave also votes to oppose policies that it believes result in corporate collaboration with strategic competitors to the United States in ways that undermine U.S. security.

Growth. Amberwave believes that long-term economic growth underpins the economic and political health of the United States. Amberwave therefore votes to support corporate policies that it believes encourage domestic investment, driving long-term productivity growth with healthy distributional effects for American communities. Amberwave also votes to oppose policies that it believes will undermine U.S. economic competitiveness, including anticompetitive behavior.

Privacy Policy

Amberwave Partners Research and Management, LLC

Amberwave Partners Research and Management, LLC (“Amberwave”) has implemented the following privacy policies and procedures to protect the security of your personal data and non-public confidential information. This Privacy Policy explains the kinds of personal data Amberwave collects and processes, our reasons and purposes for collecting the data, how the data will be processed and by whom, and your rights with regard to your personal data.

PLEASE NOTE: BY ACCESSING OUR WEBSITE, SUBSCRIBING TO OUR CONTENT AND/OR REQUESTING THAT WE CONTACT YOU, YOU ARE CONSENTING TO OUR COLLECTION AND PROCESSING OF YOUR PERSONAL DATA. IF YOU DO NOT CONSENT TO THESE TERMS, SIMPLY DO NOT VISIT OUR WEBSITE, SUBSCRIBE TO OUR CONTENT, OR REQUEST THAT WE CONTACT YOU.

Personal Data We Collect and Process

We collect your personal data any time you visit our website, request that we contact you, sign up for our content, or provide personal information to us in order to receive our services. We collect, among other things, information relating to your first and last name, your email address, your organization name, your country of residence, and your title (when appropriate). From time to time we may also collect personal data through the use of survey forms, contact forms, or when you request copies of our research documents and whitepapers or download content from our website. We collect and process your personal data in connection with your on-going relationship to Amberwave such as through correspondence, telephone calls, or other forms of contact.

We also collect data we receive automatically from your web browser or mobile devices, which may include the name of the website from which you entered our website, if any, as well as the name of the website you visit when you leave our site. This information may include the internet protocol (“IP”) address of your computer or proxy server that you use to access the internet, your internet provider name, your web browser type, the make and model of your computer or mobile device, and your operating system. We may monitor your activity on our website for any lawful purpose; however, you may visit our website anonymously.

Our Reasons for Collecting Your Data

Your personal data is collected so that we may provide you with the information you request. The information and data we collect may be used, without limitation, in any one or more of the following ways, including:

  • Processing of contact and content subscription requests
  • Improving user experiences with our website and online content
  • Improving customer service and support
  • Monitoring the use and visits to our website
  • Conducting statistical analysis and market research
  • Response to and evaluation of questions and/or complaints
  • Maintaining appropriate business records
  • Establishing, exercising, or defending against legal claims
  • Establishing and ensuring our compliance with data protection regulations and laws
  • Communicating with you through our direct marketing activities
  • Improving and maintaining our website, products, and services
 

Your personal data – whether public or private – will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever without your consent except as stated below or unless sharing your personal data is necessary to deliver a product or service you have requested from us. We reserve the right to collect and use any non-personal data made available to us by your use of our website. We further reserve the right to aggregate such data for our internal analytics, which help us improve our website and service, and we may share – or sell – our data aggregations with and to others. At no time is your personally identifiable data included in such data aggregations.

Who May Access Your Data

From time to time, we may disclose your personal data to recipients in connection with the purposes stated above, including:

  • Amberwave personnel;
  • Third-parties who we engage to provide services to us, such as information technology service providers, which may collect and process your personal data confidentially on our behalf;
  • Third-party financial institutions and licensors of our services; and/or
  • Auditors, or other regulatory authorities as requested or required by law.

Whenever we engage third-parties to provide services that may involve the collection or processing of your personal data, we require that they agree to abide by the terms of our privacy policy and comply with all applicable laws and regulations regarding the use of personal data.

Cookies and Re-Targeting Tools

Our website uses “cookies” to identify the areas of our website that you have visited. A cookie is a small piece of data stored on your computer or mobile device by your web browser that allows us to recognize your browser and collect and remember information. We use cookies to personalize the content that you see on our website and to compile aggregate data about site traffic and site interaction so that we can improve our website and provide you with a better online experience.

Your Rights

We collect your data in order to provide you with our services, but also to improve the service we provide. Your help in this regard is appreciated, and we continually work to protect your data privacy rights, including, among other things, the following:

  • Lawfulness, fairness, and transparency: we only collect and process personal data in a manner that is lawful, fair, and transparent to you.
  • Purpose limitation: we only collect personal data for the reasons and in the ways stated above, and we do not process personal data in any way that is incompatible or at odds with those purposes.
  • Minimization: we only collect personal data that is adequate, relevant and limited to what is necessary to achieve our stated purposes.
  • Accuracy: we attempt to keep your personal data accurate and up to date, and from time to time we may request that you confirm the accuracy of your data.
  • Storage limitation: we keep your data no longer than is necessary to achieve the stated purposes and/or long enough continue providing you with the service or information you have requested from us.
  • Integrity and confidentiality: we take reasonable and appropriate steps to ensure the security of your personal data and to protect against unauthorized processing or accidental loss or destruction of your data.
  • Accountability: we document our activities to show how we protect your data.
  • Portability: we respect the fact that your data is your data. If you want us transfer your personal data to you or to someone else, contact us and we will work with you to send the data where you want it in the format needed.
  • Right to be forgotten: if you want us to delete some or all of your information, simply let us know and we will honor your request as quickly as possible.

Consent

We will not use your personal data for any reason without your consent. By using our website, subscribing to our content, or otherwise submitting your personal data to us you consent to (1) our collection and processing of your data, (2) our use of such data in accordance with our stated purposes, (3) the terms of this privacy policy, and (4) the terms and conditions set forth in our limited license and use policy available at www.jsgfunds.com. If you do not consent to these terms, simply do not visit our website, subscribe to our content, request that we contact you, submit an online form to us, or download content from our website.

Withdrawal of Consent

You may withdraw your consent at any time by simply emailing us at [email protected].

Opt-Out

You may limit us or our affiliates from marketing products or services to you based on the information that we collect and share with such affiliates. Your choice to limit marketing offers will apply until you tell us to change your choice. If you have already made a choice to limit marketing offers from our affiliates, you do not need to act again until you receive the renewal notice.

To limit marketing offers or our use of your personal data, contact us by sending an email to [email protected], and we will work to implement your requested limitations.

Contact Us

Feel free to contact us at any time for any reason using the following information:

Email: [email protected]

Terms of Use

Use of this website is governed by the following terms and conditions. Please read these terms and conditions carefully, as by accessing this site you will be deemed to have agreed to them. These terms and conditions are subject to change without notice to you, so we recommend that you review them regularly. If you do not agree with these terms and conditions, do not use this site.

Limited License and Use

Amberwave Partners Research and Management, LLC (“Amberwave”) grants you a limited license to display the contents of this site on your computer or other electronic device you use to access this site, and print, download and use the materials on this site solely for informational purposes or to transact with Amberwave, provided that the contents of the site are not modified in any way and that all copyright and other notices are maintained. You agree not to, directly or indirectly, attempt or actually disrupt, impair or interfere with, alter or modify this site or any of its content.

Amberwave may utilize third-party service providers to provide certain tools and/or programs, some of which may be housed on a third-party server or on a site which has been independently developed by others. As such, while accessing this site you may be linked to such other third party servers. Access to other sites or use of any third party tools or programs on this site are subject to all terms and conditions found therein.

Past performance is not a guarantee of future results. The value of investments may go down as well as up and potential investors may not get back the amount originally invested. Amberwave makes no assurance that investment products will provide positive investment returns. A decision to invest in any such investment fund or other investment vehicle should not be made in reliance on any of the statements set forth in this document. Amberwave is not in a position to give advice on the suitability of any investments for potential investors. Prospective investors are advised to make an investment in any such fund or other vehicle only after carefully considering the risks associated with investing in such funds, as detailed in an offering memorandum or similar document that is prepared by or on behalf of the issuer of the investment fund or other vehicle.

It is not intended that anything stated on this website should be construed as an offer or invitation to buy or sell any investment in any investment fund or other investment vehicle referred to in this website, or for potential investors to engage in any investment activity.

The content on this website has been prepared solely for informational purposes based upon information generally available to the public from sources believed to be reliable. No content contained in these materials (including index data, ratings, credit-related analyses and data, model, software or other application or output therefrom) or any part thereof (the “Content”) may be modified, reverse-engineered, reproduced or distributed in any form by any means, or stored in a database or retrieval system, without the prior written permission of Amberwave. The Content shall not be used for any unlawful or unauthorized purposes. Amberwave and its third-party data providers and licensors (collectively, the “Amberwave Parties”) do not guarantee the accuracy, completeness, timeliness or availability of the Content. Amberwave Parties are not responsible for any errors or omissions, regardless of the cause, for the results obtained from the use of the Content. The content is provided on an “as is” basis.

Amberwave Parties disclaim any and all express or implied warranties, including, but not limited to, any warranties of merchantability or fitness for a particular purpose or use, freedom from bugs, software errors or defects, that the content’s functioning will be uninterrupted or that the content will operate with any software or hardware configuration. In no event shall Amberwave Parties be liable to any party for any direct, indirect, incidental, exemplary, compensatory, punitive, special or consequential damages, costs, expenses, legal fees, or losses (including, without limitation, lost income or lost profits and opportunity costs) in connection with any use of the Content even if advised of the possibility of such damages. Amberwave Parties and their respective employees, affiliates and partners hereby exclude, to the extent permitted by applicable law, all liability in connection with the use of this website.

Availability

This site, in whole or in part, may periodically be unavailable to you in order to allow for maintenance or updates, or due to other causes, including causes beyond the control of Amberwave. Further, any or all of the services on this site may change at any time, with or without notice to you.

Social Media Disclaimer

Amberwave and its employees, interns, investors, panel of industry experts, and other affiliated entities’ use of social media is for informational purposes only. No post, tweet, retweet, like, or any other interaction is a recommendation to buy or sell securities.

Amberwave is not responsible for the accuracy and/or completeness of any third-party information it shares or links to on any of its social media platforms.

With respect to any mention of performance results, be advised that past performance is not a guarantee of future results.