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Procedure for Breach of Disclosure
Due to the critical and time-sensitive nature of such incidents, the EIs should always report
them by phone or email immediately. Booklet comments are not in themselves adequate
for this type of issue.

1. The EI should attempt to have the buy side client tell us which sell side Firm talked
to them about their answers on a Greenwich Associates survey. There is
understandable reluctance for a client to do this at times. At the very least, the EI
should try and identify the study/topic around which the disclosure occurred.

2. The Buy Side Marketing member who receives the issue will record the Disclosure
Issues on the SharePoint Log and see that it is assigned to an appropriate
Marketing Manager or Relationship Manager (MM/RM) for coordination.

3. In all cases, the MM/RM will forward to the appropriate Client Associate for the
following research:

Where a client has been named
i. Confirm that the allegation is possible (the client had access to the
product and buy side data)
ii. Confirm what level of disclosure the buy side client agreed to

Where NO client has been named
i. Using the comkey and buy side client contact, in AxA or IAP data,
see which providers were "used”
ii. Cross reference the resulting list of providers with our client list
iii. Confirm what level of disclosure the buy side client agreed to
iv. This will give us a list of "likely suspects" and whether they may
have violated confidentiality

Provide this information back to the MM/RM contact handling the case for
inclusion in the incident log and possible confirmation with the buy side
client.

4. When a specific client is clearly identified and substantiated, the MM/RM will provide
the details of the case to the Managing Director Consultant in charge of the
relationship along with the Managing Director of Operations. The consultant will be
expected to call the sell side client about the alleged breach in confidentiality and
ensure that an appropriate action plan is documented and followed. For example:

A reminder of the agreement's terms
A lesson on how to best use IAPs or AxAs
A call by senior management at the client to the buy side client
A statement on the consequences of further infractions

5. A consultant or the MM/RM will follow up with the buy side client to reiterate GA's
disclosure policy and how seriously we take breaches in confidentiality, etc. The
MM/RM owner of the case is responsible for following on the actions that need to be
taken regarding the issue, keeping the issue log up-to-date, and closing it at
resolution.

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