ALESCO ADVISORS LLC
EMPLOYEE SOCIAL MEDIA POLICY
Effective April 1, 2017
At Alesco Advisors, we understand that social media can be a fun and rewarding way to share your life and opinions with family, friends and co-workers around the world. However, use of social media also presents certain risks and carries with it certain responsibilities. To assist you in making responsible decisions about your use of social media, we have established these guidelines for appropriate use of social media.
This policy applies to all associates who work for Alesco Advisors. Managers and supervisors should use our supplemental social media firm-level policies for additional guidance in administering a broader social media policy.
In the rapidly expanding world of electronic communication, social media can mean many things. It includes all means of communicating or posting any sort of digital information or content via the Internet, including to your own or someone else’s blog, journal, diary, personal website, social networking or affinity website, web bulletin board or a chat room, whether it is associated or affiliated with Alesco Advisors or not, as well as any other form of electronic communication. The same principles and guidelines found in Alesco Advisors policies apply to your activities online. Ultimately, you are solely responsible for what you post online. Before creating online content, consider some of the risks and rewards that are involved. Keep in mind that any conduct that adversely affects your job performance, the performance of fellow associates or otherwise adversely affects members, clients, suppliers, people who work on behalf of Alesco Advisors or Alesco Advisors’ legitimate business interests may result in disciplinary action up to and including termination.
Know and follow the rules
Carefully read all Alesco compliance and human resources policies, and ensure your posts are consistent with them. Inappropriate postings that may include discriminatory remarks, harassment, and threats of violence or similar inappropriate or unlawful conduct will not be tolerated and may subject you to disciplinary action up to and including termination.
Specifically, best practices within financial services social media guidelines prohibit financial services representatives from recommending, liking or otherwise endorsing third-party posts relating to the industry. Employees are also prohibited from involving themselves in the preparation of third-party content, explicitly or implicitly endorsing such content, or paying for the creation of such content, if said content can be seen to have an inappropriate financial benefit to the organization or the individual.
Employees should be aware of the SEC’s regulations related to facilitating, accepting, and promoting third-party endorsements and testimonials. Rule 206(4)-1(a)(1) states that “it shall constitute a fraudulent, deceptive, or manipulative act, practice, or course of business…for any investment adviser…to publish, circulate, or distribute any advertisement which refers, directly or indirectly, to any testimonial of any kind concerning the investment adviser or concerning any advice, analysis, report, or other service rendered by such investment adviser.” Social media, by its very nature, is considered advertising under the SEC definition, and therefore, the same rules apply to employee social media accounts that apply to direct Alesco marketing – the use of testimonials or public endorsements is prohibited. If employees are creating posts related to Alesco business, it must be reported to the firm’s compliance department to determine if such activity needs to be pre-cleared and archived in accordance with the firm’s books and records policies.
Always be fair and courteous to fellow associates, clients, members, suppliers or people who work on behalf of Alesco Advisors. Also, keep in mind that you are more likely to resolve work-related complaints by speaking directly with your co-workers, face-to-face, than by posting complaints to a social media outlet. Nevertheless, if you decide to post complaints or criticism, avoid using statements, photographs, video or audio that reasonably could be viewed as malicious, obscene, threatening or intimidating, that disparage clients, members, associates or suppliers, or that might constitute harassment or bullying. Examples of such conduct might include offensive posts meant to intentionally harm someone’s reputation or posts that could contribute to a hostile work environment based on race, sex, disability, religion or any other status protected by law or company policy.
Be honest and accurate
Make sure you are always honest and accurate when posting information or news, and if you make a mistake, correct it quickly. Be open about any previous posts you have altered. Remember that the Internet archives almost everything; therefore, even deleted postings can be searched. Never post any information or rumors that you know to be false.
Post only appropriate and respectful content
Maintain the confidentiality of Alesco Advisors clients, company trade secrets and private or confidential information. These may include information regarding systems, processes, products, know-how and technology. Do not post internal reports, policies, procedures or other internal business-related confidential communications.
Respect financial disclosure laws. It is illegal to communicate or give a “tip” on inside information to others so that they may buy or sell stocks or securities. Such online conduct may also violate the Insider Trading Policy.
Do not create a link from your blog, website or other social networking site to the Alesco Advisors website without identifying yourself as an Alesco associate.
Express only your personal opinions. Never endorse a financial product or service, or represent yourself as an Alesco spokesperson. If Alesco is the subject of the content you are creating, be clear and open about the fact that you are an associate and make it clear that your views do not represent those of Alesco, fellow associates, members, clients, suppliers or people working on behalf of Alesco. Additionally, ensure it has been reviewed and approved by Alesco’s appropriate compliance officer(s) prior to posting. If you do publish a blog or post online related to the work you do or subjects associated with Alesco, make it clear that you are not speaking on behalf of Alesco. It is best to include a disclaimer such as “The postings on this site are my own and do not necessarily reflect the views of Alesco Advisors.”
Using social media at work
Refrain from using social media while on work time or on equipment we provide, unless it is work-related as authorized by your manager and approved by authorized Alesco Advisors compliance officer. Do not use Alesco Advisors email addresses to register on social networks, blogs or other online tools utilized for personal use.
Retaliation is prohibited
Alesco Advisors prohibits taking negative action against any associate for reporting a possible deviation from this policy or for cooperating in an investigation. Any associate who retaliates against another associate will be subject to disciplinary action, up to and including termination.
Associates should not speak to the media on Alesco Advisors’ behalf without contacting an Executive Management Team member. All media inquiries should be directed to them.
For more information
If you have questions or need further guidance, please contact Alesco Advisors’ compliance or human resources representatives.
 Employees are encouraged to review the SEC guidance on this topic found at https://www.sec.gov/investment/im-guidance-2014-04.pdf.
 General statements about the market (as long as is not considered investment advice), interactions with colleagues about non-business related activities, and reference to employees’ place of employment would generally not be considered activity that needs to be reported to compliance.