Client Information Security Clause Samples

Client Information Security. It is generally expected that the Sub-Adviser shall not be provided with Shareholder Information (as defined below); however, in the event that the Sub-Adviser agrees to receive this information, then pursuant to the ▇▇▇▇▇-▇▇▇▇▇-▇▇▇▇▇▇ Act, the Sub-Adviser will implement reasonable measures that are designed to: 1) Ensure the security and confidentiality of any of the Fund’s shareholder personal information (“Shareholder Information”) in Sub-Adviser’s possession or control; 2) Protect against any anticipated threat or hazards to the security or integrity of Shareholder Information; 3) Protect against unauthorized access to or use of Shareholder Information that could result in substantial harm or inconvenience to any Fund shareholder; and 4) Ensure the proper disposal of Shareholder Information. The Sub-Adviser also agrees to notify Adviser as soon as possible of any security breach or acquisition of Shareholder Information by an unauthorized person.

Client Information Security. Pursuant to the ▇▇▇▇▇-▇▇▇▇▇-▇▇▇▇▇▇ Act, the Advisor agrees to implement reasonable measures that are designed to: 1) Ensure the security and confidentiality of any of Trustee’s consumer customer information in Advisor’s possession or control; 2) Protect against any anticipated threat or hazards to the security or integrity of this information; 3) Protect against unauthorized access to or use of this information that could result in substantial harm or inconvenience to any consumer customer of Trustee; and 4) Ensure the proper disposal of this information. The Advisor also agrees to notify Trustee as soon as possible of any security breach or acquisition of its client’s personal data by an unauthorized person.

Client Information Security. Pursuant to the ▇▇▇▇▇-▇▇▇▇▇-▇▇▇▇▇▇ Act, to the extent that the services provided by the Sub-Adviser under this Sub-Advisory Agreement require that the Sub-Adviser have possession or control of any Shareholder Information (as defined below) and the Sub-Adviser actually has possession or control of any such Shareholder Information, the Sub-Adviser agrees to implement reasonable measures that are designed to: 1) Ensure the security and confidentiality of any of the Fund’s shareholder personal information (“Shareholder Information”) in Sub-Adviser’s possession or control; 2) Protect against any anticipated threat or hazards to the security or integrity of Shareholder Information; 3) Protect against unauthorized access to or use of Shareholder Information that could result in substantial harm or inconvenience to any Fund shareholder; and 4) Ensure the proper disposal of Shareholder Information. The Sub-Adviser also agrees to notify Adviser as soon as possible after the Sub-Adviser becomes aware of any security breach or acquisition of Shareholder Information in Sub-Adviser’s possession or control by an unauthorized person.

Client Information Security. Pursuant to the ▇▇▇▇▇-▇▇▇▇▇-▇▇▇▇▇▇ Act, the Sub-Adviser agrees to implement reasonable measures that are designed to: 1) Ensure the security and confidentiality of any of the Fund’s shareholder personal information (“Shareholder Information”) in Sub-Adviser’s possession or control as a result of performing services under this Agreement; 2) Protect against any anticipated threat or hazards to the security or integrity of Shareholder Information; 3) Protect against unauthorized access to or use of Shareholder Information that could result in substantial harm or inconvenience to any Fund shareholder; and 4) Ensure the proper disposal of Shareholder Information. The Sub-Adviser also agrees to notify Adviser as soon as possible of any security breach or acquisition of Shareholder Information by an unauthorized person of which the Sub-Adviser becomes aware. PHTRANS/ 484468.2 NTAC:3NS-20 NTAC:3NS-20

Client Information Security. In the event that the Adviser provides any of the Fund’s shareholder personal information (“Shareholder Information”) to the Sub-Adviser, the Sub-Adviser agrees to notify the Adviser of such occurrence and to immediately destroy or return such Shareholder Information.

Client Information Security. Pursuant to the ▇▇▇▇▇-▇▇▇▇▇-▇▇▇▇▇▇ Act, to the extent that the services provided by the Sub-Adviser under this Sub-Advisory Agreement require that the Sub-Adviser have possession or control of any Shareholder Information (as defined below) and the Sub-Adviser actually has possession or control of any such Shareholder Information, the Sub-Adviser agrees to implement reasonable measures that are designed to: 1) Ensure the security and confidentiality of any of the Fund’s shareholder personal information (“Shareholder Information”) in Sub-Adviser’s possession or control; 2) Protect against any anticipated threat or hazards to the security or integrity of Shareholder Information; 3) Protect against unauthorized access to or use of Shareholder Information that could result in substantial harm or inconvenience to any Fund shareholder; and 4) Ensure the proper disposal of Shareholder Information. The Sub-Adviser also agrees to notify the Adviser as soon as possible after the Sub-Adviser becomes aware of any security breach or acquisition of Shareholder Information in Sub-Adviser’s possession or control by an unauthorized person. This Agreement shall be governed by and interpreted in accordance with the laws of the State of Illinois. NORTHERN TRUST INVESTMENTS, INC. By: /s/ ▇▇▇▇ ▇. ▇▇▇▇▇▇ Name: ▇▇▇▇ ▇. ▇▇▇▇▇▇ Title: Senior Vice President PANAGORA ASSET MANAGEMENT INC. By: /s/ ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ Name: ▇▇▇▇▇ ▇. ▇▇▇▇▇▇▇ Title: General Counsel Sub-Advisory Fees As full compensation for the services and the expenses assumed by the Sub-Adviser pursuant to this Agreement, the Sub-Adviser shall be entitled to a fee paid by the Adviser and determined in accordance with the following provisions: