Clockwise Capital prioritizes the secure and ethical use of artificial intelligence (AI) to enhance our services while safeguarding client information. Our policy strictly prohibits sharing passwords with AI tools and entering client non-public personal information (NPI) without explicit authorization. We work exclusively with AI providers that demonstrate robust data protection, commit to not retaining or selling client information, and immediately notify us of any breaches. These providers must also indemnify our firm against violations and provide annual compliance confirmations. Employees are required to acknowledge this policy regularly and adhere to rigorous standards to ensure the integrity of our processes and the trust of our clients.
Clockwise Capital subscribes to QuantStreet Capital’s model portfolios; Clockwise is a client of QuantStreet. Clockwise and QuantStreet also work together to offer outside chief investment officer (OCIO) services to other asset managers. This relationship may create a conflict of interest by incentivizing the parties to promote each other. QuantStreet develops model portfolios that integrate certain Clockwise strategies in exchange for 10% of the fee that Clockwise charges applicable clients. Clockwise and QuantStreet also share fees, as determined on a case by case basis, when clients retain them to provide OCIO services. Since each of the parties receives a financial benefit when clients use the model portfolios and OCIO services, the parties are incentivized to promote each other. This may create a conflict of interest.
