Business Practice

Anti-Money-Laundering Program

Following the attacks on 11 September 2001, the U.S. government enacted the USA PATRIOT Act, which is designed to prevent the use of the U.S. financial system to help fund terrorism and other crimes. The Act, which is similar to regulations in other countries in which we do business, imposes a series of new anti-money-laundering requirements on brokerage firms and other financial institutions. GOODWIN has had a vigorous money-laundering prevention program in place for years. In accordance with the Act, we have undertaken efforts to further enhance these existing policies and procedures. We believe that compliance with the new regulations is of the utmost importance, and have dedicated significant resources to ensure that GOODWIN helps set the standard for best practices in this area. We have dedicated ourselves to enhancing our existing efforts in the fight against money laundering around the globe.

As a firm with businesses around the world, we have been working closely with all our business partners to ensure that we comply with all anti-money-laundering efforts wherever we operate. We are implementing an enterprise-wide suspicious activity reporting system that will enable us to better report suspicious activity to the government. All of our employees are being trained in anti-money-laundering practices and procedures, as well as the details of GOODWIN 's policies.

At GOODWIN, we have always stressed the importance of knowing our clients. This action has developed not only from regulatory requirements but also from the belief that the better we know our clients, the better we can serve their financial needs. We may ask clients for additional information and documentation about certain accounts and transactions. This information may be used to verify client identity.

Business Continuity Statement

GOODWIN is responsible for creating and maintaining business continuity plans for all of its businesses.  In the event of a business disruption, we have plans designed to allow us to continue operations of critical business functions, such as entering of client orders, completing securities transactions and providing clients access to their cash and securities. We accomplish this in part by:

l          Relocating impacted businesses to designated recovery locations.

l          Using redundant processing capacity at other locations.

l          Designing our technology and systems to support the recovery processes for critical business functions and managing the recovery process.

l          Adopting a communication plan to ensure that GOODWIN employees receive emergency notifications and instructions via a variety of sources, including in-building announcements, telephone contact and websites.

Rehearsing our recovery procedures and testing those procedures on a regular basis.

Although we have taken significant steps to develop and implement sound business recovery plans, we cannot guarantee that systems will always be available or recoverable after a disaster or significant business disruption.  However, we believe that our planning for such events is robust and consistent with many of the best practices established within the industry.  Any material changes to the above information will be available on our website or upon request.

Environmental Policy Statement

GOODWIN is committed to environmental excellence and, as a matter of longstanding policy, recognizes the importance of protecting the global ecosystem, reducing the use of natural resources and encouraging investment in ways that support responsible and sustainable development. GOODWIN¡¯s environmental policy is intended to create long-term positive environmental benefits and conserve natural resources, including minimizing energy and water consumption wherever possible.

GOODWIN engages in waste minimization practices. GOODWIN recycles or reuses natural resources and encourages employees to extend its recycle/reuse program to offices, cafeterias and community activities. GOODWIN communicates to its employees the importance of pollution prevention through waste reduction, reuse and recycling, and encourages employee involvement in environmental issues. GOODWIN works with communities and municipalities to find new ways of reducing the environmental impact of our operations.