LEGAL & COMPLIANCE
BUSINESS NAMES

TPH&Co. and Tudor, Pickering, Holt & Co. are the global brand names for Perella Weinberg Partners LP, Tudor, Pickering, Holt & Co. Securities, LLC (“TPHS”) and Tudor, Pickering, Holt & Co. Securities – Canada, ULC (“TPHC”).

BUSINESS CONTINUITY PLAN

We have designed a business continuity plan (“BCP”) to evaluate and manage potential significant disruptions to our business operations so that we may continue critical business functions in the event of an emergency. Critical functions include the storage and preservation of data, order taking, order entry, execution, comparison, allocation, clearance and settlement of securities transactions, the maintenance of customer accounts, access to customer accounts, the delivery of funds and securities, alternate communications with clients and regulators, and alternate communications with employees. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

In the event of a significant business interruption, we will assess which means of communication are still available to us and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. For example, if we have communicated with a party by email but the Internet is unavailable, we will call them on the telephone and follow up where a record is needed with paper copy through the US or Canadian mail service or rapid delivery service.

The BCP was designed after reviewing the potential risks and ability to recover from key losses. The BCP is reviewed, updated, and tested at least annually. The BCP includes discussion of potential disruptions including loss of one or more offices, loss of communication services, loss of power, loss of key personnel, and loss of key service providers. Our BCP addresses: data backup and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, bank, and counter-party impact; regulatory reporting; and assurance of customers’ prompt access to funds and securities custodied by our clearing agents in the event we are unable to continue business.

We utilize our various off-site locations to replicate critical data and technology. In the event of a significant disruption, it is our goal to recover from the disruption within 24 hours or less so that we can continue business operations. We intend to respond to such disruptions by safeguarding our employees and property, making a financial and operational assessment, and protecting the firm’s books and records. 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.

Significant business disruptions can vary in their scope. A disruption may affect only our firm, a single building housing one of our firm’s offices, the business district where one of our firm’s offices is located, the city where one of our firm’s offices is located, or a whole region where one or more of our firm’s offices are located. 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 one of our firm’s offices, we will make every effort to transfer our operations to a local site when needed and expect to recover and resume business within 24 hours or less. In a disruption affecting a business district, city, or region including one or more of our offices, we will transfer our operations to a site outside of the affected area and recover and resume business within 24 hours or less. In either situation, we plan to continue in business, and notify you on how to contact us through our web site. The nature of the BCP is to lessen the impact of emergencies. Because events that bring about disruptions are unpredictable, we may have no ability to restore full service in the event of failures in certain infrastructure such as utilities, communication networks, transportation, and third-party providers. We do not guarantee that we will be able to continue or resume business operations within any specified period of time under all circumstances.

In the event of a significant business disruption, customers of Tudor, Pickering, Holt & Co. Securities – Canada, ULC may contact a Client Service Representative at our carrying broker (Fidelity Canada Clearing ULC) regarding all trade settlement related issues as follows;

Toll Free: 1-800-263-4077 or 1-416-307-5200.

For more information, to request a written copy of our BCP, or if you have questions about our business continuity planning, you can contact us as follows: 

Tudor, Pickering, Holt & Co. Securities, ULC:   bcp@pwpartners.com.

Tudor, Pickering, Holt & Co. Securities – Canada, ULC: dwheatley@tphco.ca

COMPLAINTS

In the event you should have a question or complaint that you would like to register with our Firm, please contact the Compliance Department at:

Tudor, Pickering, Holt & Co. Securities, LLC
Attn: Compliance Department
1111 Bagby, Suite 4900
Houston, TX 77002 USA
(713) 333-7130

Tudor, Pickering, Holt & Co. Securities – Canada, ULC
Attn: Compliance Department
Suite 2110, 250 – 6th Avenue SW
Calgary, AB T2P 3H7
(403) 705-7837

COPYRIGHT TERMS OF USE

© TPH&Co. 2022. No person may reproduce any portion of the content on this website without prior written consent of TPH&Co. “Content” refers to any materials, documents, images, graphics, logos, design, audio, video and any other information provided from or on our site.

EMAIL DISCLOSURE

Email is confidential and is intended only for the individual named. The information contained in an email may not be disclosed, copied or disseminated, in whole or in part, without the prior written permission of TPH&Co. Email communications are based on information which TPH&Co. believes is reliable. However, TPH&Co. does not represent or warrant its accuracy. Email messages should not be considered as an offer or solicitation to buy or sell any securities. Securities offered through Tudor, Pickering, Holt & Co. Securities, LLC, Member FINRA/SIPC and Tudor, Pickering, Holt & Co. Securities – Canada, ULC, Member IIROC/CIPF.

Under FINRA Rule 2210, Tudor, Pickering, Holt & Co. Securities, LLC (“TPHS”) email communications are deemed institutional sales material and are not meant for distribution to retail investors. Recipients should not forward TPHS email communications to a retail investor.

INFORMATION SHARING FOR MARKETING PURPOSES

Federal law gives you the right to limit information sharing between affiliated entities for marketing purposes. It also requires us to give you this notice to tell you about your choices to limit information sharing for marketing purposes.

This notice is being provided on behalf of Tudor, Pickering, Holt & Co. Securities, LLC. You may limit our affiliates from marketing products or services to you based on your personal information that they collect and share with one another. This information includes your contact information, and account history.

To prohibit information sharing for marketing purposes, please contact the Compliance Department at compliance@pwparters.com or call 713-333-7100. Your instruction to limit marketing offers from our affiliates will remain in effect until you tell us to make a change.

NO OFFERS

This website is for informational purposes only and does not constitute an offer to sell or solicitation of an offer to buy any security which may be referenced on this website. Offers can only be made where lawful under applicable law.

PRIVACY POLICY

TPH&Co. considers your privacy our utmost concern. In order to provide you with individualized service, we collect certain personal, non-public information about you from information you provide on applications or other forms and information about your account transactions with us. We may also collect such information through your account inquiries by mail, email, or telephone.

  • Types of Information Collected by Technology. To make our website and related services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. Like most internet services, we automatically gather this information and store it in log files each time you open one of our research reports. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing one of our research reports. You can find more information about cookies at websites such as www.allaboutcookies.org and www.youronlinechoices.eu. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience. Persistent Cookies can be removed by following Internet browser help file directions. We also use Cookies, navigational data, and other means to gather information regarding the date and time and duration of your review of our research reports and the solutions and information for which you searched and which you reviewed. This information includes characters you type, your search and browsing history, research articles you click, and pages you view, and includes personally or non-personally identifiable data or information resulting from the use or access to our research reports, including, without limitation, any information collected related to your use of third party products (the “Usage Information”). Except as prohibited by law, TPH&Co. has the right to use, distribute, copy, transfer, modify, collect, extract, compile, synthesize and analyze such Usage Information for any purpose in its discretion without notice to you. We may also collect precise location information in order to enhance your use of the services. We do not respond to browser-based “do not track” signals.
  • Use of Your Data. We may use your information for any purpose in our discretion. In general, information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. TPH&Co. uses your information for research, marketing, and general purposes; identify you as a user in our system; provide improved administration of our services; improve the quality of experience when you interact with our research reports and services; send you administrative e-mail notifications; respond to your inquiries; send promotional communications; make telephone calls to you, from time to time, as a part of secondary fraud protection; and to solicit your feedback. We may create anonymous data records from information by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our services and improve site navigation. TPH&Co. reserves the right to use and disclose anonymous data to third party companies for any purpose in its discretion. If you provide feedback on any of our services to us, we may use such feedback for any purpose, provided we will not associate such feedback with your information.
  • Disclosure of Your Information. We may share some or all of your information with our affiliates, subsidiaries, joint ventures or other companies under common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company or our assets, that company will possess the information collected by it and us and will assume the rights and obligations regarding your information collected by us as described in this Privacy Policy. TPH&Co. may disclose information if it believes in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on TPH&Co.; or (b) protect or defend the rights or property of TPH&Co. or users of the services. We may share your information with third party service providers to provide you with the services that we offer you. We also may enter into agreements with third party companies. A third party company may want access to information that we collect from you and we may share such information with a third party.

We do not disclose any nonpublic personal information about you to anyone, except as permitted by law. Specifically, so that we may continue to offer you products and services that best meet your investing needs, and to effect transactions that you request or authorize, we may disclose the information we collect, as described above, to companies that perform administrative or marketing services on our behalf, such as transfer agents, or printers and mailers that assist us in the distribution of investor materials. These companies will use this information only for the services for which we hired them, and are not permitted to use or share this information for any other purpose.

If you decide at any point either to end your relationship with us or to become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice.

With regard to our internal security procedures, we restrict access to your personal and account information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.

SOCIAL MEDIA DISCLOSURES
TWITTER

TPH&Co. and its affiliated companies reserve the right to retain, monitor, and reproduce all electronic communications consistent with applicable law. Tudor, Pickering, Holt & Co. and TPH&Co. are the trade names for Tudor, Pickering, Holt & Co. Securities, LLC, Member of FINRA & SIPC and Tudor, Pickering, Holt & Co. Securities – Canada, ULC Member of IIROC & CIPF. Neither the information, nor any opinion, nor any other content on this site constitutes a solicitation or offer by TPH&Co. or its affiliates to buy or sell any securities, options, or other financial instruments or provide any investment advice or services. TPH&Co. will not accept purchase or sales orders via Twitter or any social media systems, and reminds all users not to disclose any personal financial information on Twitter. TPH&Co. is not responsible for third parties that may be linked to this page or to other Twitter pages, including but not limited to content posted by third parties, the privacy and security policies of Twitter or any other third-party sites, or for the products or services offered by any third party.

LINKEDIN

TPH&Co. and its affiliated companies reserve the right to retain, monitor, and reproduce all electronic communications consistent with applicable law. Tudor, Pickering, Holt & Co. and TPH&Co. are the trade names for Tudor, Pickering, Holt & Co. Securities, LLC , Member of FINRA & SIPC and Tudor, Pickering, Holt & Co. Securities – Canada, ULC, Member of IIROC & CIPF. Neither the information, nor any opinion, nor any other content on this site constitutes a solicitation or offer by TPH&Co. or its affiliates to buy or sell any securities, options, or other financial instruments or provide any investment advice or services. TPH&Co. will not accept purchase or sales orders via LinkedIn or any social media messaging systems, and reminds all users not to disclose any personal financial information on LinkedIn. TPH&Co. is not responsible for third parties that may be linked to this page or to other LinkedIn pages, including but not limited to content posted by third parties, the privacy and security policies of LinkedIn or any other third-party sites, or for the products or services offered by any third party. 

FACEBOOK

TPH&Co. and its affiliated companies reserve the right to retain, monitor, and reproduce all electronic communications consistent with applicable law. Tudor, Pickering, Holt & Co. and TPH&Co. are the trade names for Tudor, Pickering, Holt & Co. Securities, LLC, Member of FINRA & SIPC and Tudor, Pickering, Holt & Co. Securities – Canada, ULC, Member of IIROC & CIPF. Neither the information, nor any opinion, nor any other content on this site constitutes a solicitation or offer by TPH&Co. or its affiliates to buy or sell any securities, options, or other financial instruments or provide any investment advice or services. TPH&Co. will not accept purchase or sales orders via Facebook or any electronic messaging systems, and reminds all users not to disclose any personal financial information on Facebook. TPH&Co. is not responsible for third parties that may be linked to this page or to other Facebook pages, including but not limited to content posted by third parties, the privacy and security policies of Facebook or any other third-party sites, or for the products or services offered by any third party. All statements and messages are for U.S. residents only.

Research

For detailed rating information, distribution of ratings, price charts and disclosures regarding compensation policy and investment banking revenue, please visit https://tphco.bluematrix.com/sellside/Disclosures.action.

Securities
Best Execution & Order Handling

As an IIROC Dealer Member, Tudor, Pickering, Holt & Co. Securities – Canada, ULC (“TPHC”) is required to establish, maintain and ensure compliance with written policies and procedures that are reasonably designed to achieve best execution when acting for a client.  TPHC uses the facilities of three executing brokers when routing orders to the various marketplaces in Canada.  Below are links to their best execution policies and procedures. 

Virtu Financial

RBC Capital Markets

BMO Nesbitt Burns

BrokerCheck

FINRA Rule 2267 requires that member firms provide clients with the FINRA BrokerCheck Hotline Number (800-289-9999), FINRA web site address (www.finra.org) and a notification that a brochure describing BrokerCheck is available from FINRA by contacting FINRA through their web site.

CUSTOMER IDENTIFICATION PROGRAM NOTICE

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 DOES THIS REQUIREMENT MEAN TO YOU?

When you open an account, we will ask for your name, address, date of birth and identification number. The identification for a U.S. citizen would be a taxpayer identification number or social security number. For a non-U.S. citizen, the identification number would include a (i) taxpayer identification number, (ii) a passport number along with country of issuance, (iii) alien identification number, or (iv) a government-issued identification document indicating nationality, residence, as well as your photo. We may also ask to see or copy your driver’s license, passport, or other identifying documents.

A corporation, partnership, trust, or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement, or a trust agreement.

QUESTIONS? COMMENTS?

If you should have any questions or comments about our Customer Identification Program, please contact our Compliance Department on 713-333-7100. You may write to us at the following address:

Tudor, Pickering, Holt & Co. Securities, LLC
Attn: Compliance Department
1111 Bagby, Suite 4900
Houston, Texas 77002

ORDER ROUTING

Absent specific order routing instructions from customers, TPHS transmits orders to various market centers based on a number of factors. Such factors may include the following: the ability of a market center to execute the orders at or superior to the national best bid and offer (NBBO); the ability of a market center to provide price improvement opportunities; the speed of execution; the availability of efficient, automated transaction processing; liquidity enhancement opportunities; the speed of displaying better-priced limit orders; trading characteristics of the particular securities; and the extent to which different markets may be more suitable for different types of orders or different securities.

PAYMENT FOR ORDER-FLOW DISCLOSURE

TPHS does not engage in any formal arrangement for the payment for order flow from securities transactions. From time to time, when TPHS routes orders to a particular market center and is in a position to provide liquidity, a market center may provide TPHS with a rebate for that order flow.

SEC RULE 13H-1 – LARGE TRADER RULE

The Large Trader Rule requires large traders to register with the SEC and obtain a large trader ID. The Large Trader Rule defines a large trader as any person that:

  • Directly or indirectly, including through other persons controlled by such person, exercises investment discretion over one or more accounts and effects transactions for the purchase or sale of any NMS security for or on behalf of such accounts, by or through one or more registered broker-dealers, in an aggregate amount equal to or greater than:
  • During a calendar day, either two million shares or shares with a fair market value of $20 million; or
  • During a calendar month, either twenty million shares or shares with a fair market value of $200 million; or
  • Voluntarily registers as a large trader by filing electronically with the Commission on Form 13H. Please consult with your legal counsel to determine the applicability of the Larger Trader Rule to your activities.
SEC RULE 606 – REPORT DISCLOSURE OF ORDER ROUTING INFORMATION: CLICK HERE

Tudor, Pickering, Holt & Co. Securities, LLC (TPHS) has prepared this report disclosure pursuant to U.S. Securities and Exchange Commission Rule 606 requiring all brokerage firms to publicly disclose, on a quarterly basis, reports on the top execution venues to which certain orders are routed for execution. The report provides information on the routing of “non-directed orders” – any order that the customer has not specifically instructed to be routed to a particular venue for execution. For these non-directed orders, TPHS has selected the execution venue on behalf of its customers. Currently, TPHS generally does not accept orders on a “non-directed” basis.

SIPC INFORMATION

Tudor, Pickering, Holt & Co. Securities, LLC is a member of the Securities Investor Protection Corporation (SIPC). Please be advised that you may obtain information about SIPC, including the SIPC brochure, by contacting SIPC at www.sipc.org or 202-371-8300.