Regulatory Policies & Disclosures

1. Code of Ethics & Fiduciary Duty Policy

In accordance with Rule 204A-1 under the Investment Advisers Act of 1940, Plum Creek Investment Services Inc. has adopted a comprehensive Code of Ethics establishing the standard of conduct expected of all supervised persons. Key tenets include:

• Uncompromising Loyalty: Putting client financial interests first at all times, in every circumstance, without exception.
• Personal Securities Trading Pre-Clearance: Access persons must obtain pre-clearance from the Chief Compliance Officer before executing personal trades in covered securities to prevent front-running or conflicts.
• Quarterly & Annual Holdings Reports: Mandatory reporting of all personal brokerage accounts and periodic trade confirmations for independent compliance review.
• Gift & Entertainment Thresholds: Strict prohibition on receiving gifts, travel, or entertainment valued in excess of nominal limits ($100 per year) from any vendor, fund manager, or prospective partner.

2. Regulation S-P Financial Privacy & Consumer Safeguards

We respect the confidentiality of our clients' sensitive personal and financial data. Pursuant to Title V of the Gramm-Leach-Bliley Act and SEC Regulation S-P, our policy states:

• Information We Collect: Identifying information (name, address, Social Security number, date of birth) and financial profile data (tax returns, account balances, investment objectives).
• No Selling of Information: We do NOT sell, rent, or trade client personal or financial information to any third party for marketing, promotional, or commercial purposes.
• Permitted Disclosures: Information is disclosed strictly to qualified custodians (e.g., Charles Schwab, Fidelity) solely to execute authorized trades, open custodial accounts, or comply with legal subpoenas.

3. Cybersecurity Safeguards & Data Defense

To guard against digital interception, ransomware, and identity theft, Plum Creek maintains rigorous technological safeguards across all hardware, email servers, and client document vaults:

• Hardware-Token MFA: Multi-factor authentication required across all advisor workstations, institutional custodian logins, and client portals.
• End-to-End Encryption: 256-bit AES encryption for all data stored at rest and TLS 1.3 encryption for data in transit.
• Wire Verification Protocols: Mandatory verbal call-back authentication to client phone numbers of record for all money movements or wire transfers to prevent business email compromise (BEC).
• Regular Vulnerability Audits: Periodic penetration testing and simulated phishing drills conducted by independent cybersecurity evaluators.

4. Best Execution & Soft-Dollar Prohibition

As fiduciaries, we have an obligation to seek the best execution of client trades. Factors evaluated during periodic reviews include execution speed, price improvement, commission schedules, liquidity, and custodian financial stability.

5. Conflicts of Interest & Independent Selection

Plum Creek Investment Services was established as an independent Registered Investment Advisor specifically to eliminate the structural conflicts inherent in Wall Street brokerage models:

• No Proprietary Investment Products: We manage no in-house mutual funds, structured notes, or syndicated offerings.
• No Sales Incentives or Quotas: Our advisors are compensated strictly by advisory fees aligned with client wealth growth, with zero sales quotas.
• Full Fee Transparency: All advisory fees are explicitly calculated and disclosed prior to engagement.

6. Business Continuity & Disaster Recovery Plan (BCP)

Plum Creek maintains an active Business Continuity Plan designed to ensure rapid recovery of operations during unforeseen emergencies (such as natural disasters, power grid failure, or facility disruption):

• Redundant Cloud Architecture: All portfolio management systems, financial planning engines, and CRM data are continuously backed up across geo-redundant enterprise cloud datacenters.
• Independent Custodial Access: Because client assets are held at independent custodians (Charles Schwab / Fidelity), clients retain direct 24/7 access to view holdings, withdraw funds, or place liquidating orders through custodian hotlines even if our local office is temporarily offline.

7. Client Inquiries & Complaint Resolution

We take client feedback with the highest seriousness. Any client question, concern, or formal complaint regarding our advisory services, fee billing, or staff conduct should be directed in writing to our Chief Compliance Officer:

8. Form ADV & Client Relationship Summary (Form CRS)

Form ADV Part 2A and Form CRS are filed annually with regulatory authorities. These documents contain detailed disclosures regarding our advisory services, fee schedules, disciplinary history (none), and advisor qualifications.