Privacy Policy

Stralem & Company Incorporated (“Stralem”) recognizes and appreciates the importance of respecting the privacy of our visitors. We want to assure visitors to our site the security, privacy and confidentiality that they expect from a financial services institution. Stralem is committed to safeguarding against unauthorized disclosure of, or access to your information.

Stralem does not collect any personal information from those who merely visit or browse our site. Personal information is collected if the visitor chooses to complete the questionnaire in the Stralem Contact Us section or sends us an email message.

Changes to our privacy policies may be made periodically. We recommend that visitors to our site review our privacy policies from time to time to learn of new privacy practices and changes to our policies.

E-mail and Product Inquiry - The information provided in an email message will only be used to respond to the visitor's inquiry and to provide better customer service.

Use of Information Collected - Stralem uses the information collected from visitors to its site to address the specific needs of those visitors and to provide better customer service, including the provision of the latest information regarding our products. Stralem limits the collection, retention and use of information to the minimum amount required to properly serve you.

Access to Information Collected by Stralem Employees - Stralem emphasizes to our employees the confidential nature of visitor information and the high level of importance Stralem places on maintaining confidentiality. Stralem restricts access to nonpublic personal information about visitors to those employees who need to know that information in order to respond to that visitor’s needs and provide the visitor with information regarding specific products in which the visitor may have an interest.

Third Parties - Stralem does not transmit any personal information collected through its site to any third-party marketers. To the extent that Stralem outsources processing functions and support services to unaffiliated third parties, Stralem limits the information available to them to information necessary or appropriate to offer such processing and support services. Stralem requires that these third parties hold the information Stralem provides in confidence, subject to our security standards and only for approved purposes. Stralem is satisfied that Stralem service providers maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard your nonpublic person information.

Business Continuity Plan Summary

Stralem has developed a Business Continuity Plan on how we will respond to events that could significantly disrupt our business. Due to the fact that the timing and impact of potential disasters and disruptions is unpredictable, we recognize the need for flexibility in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us – If after a significant business disruption you cannot contact us as you usually do at (212) 888-8123, you should go to our web site at www.stralem.com. If you cannot access us through either of those means, you should contact your custodian directly. If your account is custodied at our prime broker, Pershing LLC, with Pershing Adviser Solutions, LLC as introducing broker (collectively “Pershing”), you can contact them directly at (201) 413-3635 or (213) 624-6100 extension 500 or at their web site at www.pershing.com/ria/business_continuity for instructions on how limited trade-related transactions, cash disbursements, and security transfers may be processed.

Should a significant business disruption occur, we plan to respond quickly and resume business operations by safeguarding our employees and property, conducting rapid financial and operational assessments, protecting the firm’s books and records, and implementing emergency measures to allow our customers to transact business. Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical suppliers, bank and regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.

Our Business Continuity Plan – Our business continuity solution includes ongoing replication of all critical firm data to a secure external location. This provides secure access to all Stralem’s data in a ready to use, web enabled format and is accessible from anywhere in the world allowing Stralem’s employees to be geographically dispersed and continue business in the event of a crisis. Our goal is to allow for rapid “recovery” from natural or man-made disasters with the ability to focus on our business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Pershing backs up our customer records (for accounts custodied at Pershing) in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by Pershing that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within four (4) hours. This recovery objective may be negatively affected by the unavailability of external resources and circumstances beyond their control. Your transactions could be delayed during this period.

Varying Disruptions – Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within four (4) hours. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and expect to recover and resume business within four (4) hours. This recovery objective may be negatively affected by the unavailability of external resources and circumstances beyond their control. Your transactions could be delayed during this period. In either situation, we plan to continue in business, transferring operations to an alternate site if necessary, and notify you through our web site at www.stralem.com or by telephone at (212) 888-8123 on how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

Proxy Voting Policy

Rule 206(4)-6 requires investment advisers who have voting authority with respect to securities held in their clients’ accounts to monitor corporate actions and vote proxies in their client’s interests.  They must also adopt written policies and procedures, make those policies and procedures available to clients and retain certain records with respect to proxy votes cast.

Stralem subscribes to a proxy monitor and voting agent service offered by Institutional Shareholder Services, Inc. (“ISS”). ISS provides a proxy analysis with research and a vote recommendation. They also transmit votes, record and generate a voting activity report for Stralem’s clients. Generally, Stralem does not have voting authority with respect to securities held in client accounts. If Stralem were asked to vote proxies on behalf of a client, Stralem will generally vote in accordance with the recommendations of ISS, but Stralem may issue instructions to change a particular vote if Stralem determines that it is in the client’s best interest. Where applicable, Stralem will also consider any specific guidelines designated in writing by a client. Stralem does not consider its own interest as an investment adviser in making proxy voting decisions for clients. If a conflict were to arise between Stralem and client interests with respect to a matter submitted to shareholders, Stralem would refer the matter to ISS and direct that service to vote the proxy in the client’s interest. Stralem will periodically monitor and review the policies of ISS.

Stralem will generally vote against any policy that would reduce: the rights of shareholders, shareholder influence over the board of directors and management, the alignment of interests between management and shareholders, or the value of shareholders’ investments.

Important Information About Procedures for Opening A New Account

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

What this means for you: When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents.

Legal Disclaimers

No guarantee is made as to the accuracy, completeness or timeliness of any information, projections or opinions contained in this web site or upon which any such projections or opinions have been based. The information contained in this web site is compiled for the convenience of site visitors and is accepted by the site visitor on the condition that errors or omissions shall not be made the basis for any claim, demand or cause of action. The views reflected herein are subject to change without notice.

The contents of this web site is strictly for information purposes only and does not constitute an offer or solicitation to purchase or sell any of the securities mentioned in this web site. Visitors should not use this site as their sole source of information on investments. Past performance is no guarantee of future performance. Investors should note that the value of the securities mentioned herein may fall as well as rise. Decisions based on information contained herein are the sole responsibility of the user, and in exchange for using this site, the user agrees to hold Stralem harmless against any claims for damages arising from any decisions the user makes based on such information.

Contact Us:
Stralem & Company Incorporated
645 Madison Avenue
New York, NY 10022
Phone: (212) 888-8123
Fax: (212) 888-8152
Email Ms. Paccione, Chief Compliance Officer,
Director, Financial  Operations and  Administration