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Information Systems Security Program (ISSP)

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Over the years, information technology has changed nearly every aspect of how financial service companies such as Bellwether Capital Management, LP (the “Company” or “BCM”) conduct business. For example, BCM may use electronic means to collect and maintain customer and counterparty information. This information may include personally identifying information (“PII”) for individuals such as social security numbers and confidential or sensitive information for institutional customers and counterparties, including corporate records and financial information. Additionally, BCM may have websites that are available to customers and counterparties for opening accounts, trading, and accessing account information, and rely upon electronic means to enter customer, counterparty and proprietary orders. Moreover, BCM may either directly or indirectly connect electronically with other Members, exchanges, clearinghouses, third-party service providers, NFA and the CFTC. The Company has therefore established these ISSP policies which it considers are reasonably expected to create effective administrative, technical and physical safeguards designed to diligently supervise the risks of unauthorized access to or attack of their information technology systems, and to respond appropriately should unauthorized access or attack occur.

View ISSP procedures