
Borthwick Associates strives to maintain a current, complete and meaningful regulatory compliance program.
We have developed certain plans and procedures designed to address this ever changing area of the financial industry. Our Anti-Money Laundering Policy details the type of information we require from our clients. The SEC's intent of this regulation is not only to dissuade illegal activities such as money laundering and terrorist funding, but for advisors to better know their customers and ensure that account activity is suitable for each client. Our Business Continuity Plan outlines the steps we will take in the event of a significant business disruption. Our Code of Ethics describes the practices and policies of Borthwick Associates in our primary fiduciary responsibility of rendering clients an investment advisory service based on honesty, good faith and fair dealing. Our Form ADV Part II offers specific information about the size and scope of our business activities. The Borthwick Associates Privacy Policy explains how we use and protect the information our clients and counterparties share with us. And finally our Proxy Policy summarizes how and why we vote proxies on behalf of our clients. You may click on any of the following links to view that policy in its entirety.
1. AML Policy
2. Business Continuity Plan
3. Code of Ethics
4. Form ADV Part II
5. Privacy Policy
6. Proxy Procedure
Please contact Meg Davidson, Compliance Officer at megdavidson@ameritech.net or Thomas Flaig, President at tflaig@ameritech.net if you have any comments regarding our compliance program or any other matter.

