Effective Date: April 11, 2016

Social Media Policy

Purpose

The Social Media Policy describes the guidelines adopted by RockWealth, respecting the personal conduct by RockWealth Personnel while engaging in online conversations as representatives of the firm.

This Social Media Policy applies to all offices of RockWealth and to all RockWealth Personnel.

Definitions

RockWealth Personnel means all partners, principals, professionals, paralegals, staff members, interns and temporary employees of RockWealth.

Policy

As a independent financial advisor firm, RockWealth is held to a different standard when it comes to its online communications.

Certain ethical rules must be followed by all RockWealth Personnel participating in social media to keep RockWealth from violating these rules.

Most conversations on social media platforms are held in an informal manner, so strict application of the RockWealth writing style is not required for social media communications, however, professional discourse is expected. The main focus of this Social Media Policy is avoidance of the unique pitfalls online communication holds for financial professionals. In view of these facts, below are suggested guidelines and a list of things to avoid when communicating with the public via any social media outlet.

All social media accounts, blogs, Web pages and related content carrying the RockWealth brand identity are and will be owned and licensed by RockWealth as appropriate.

Personal accounts, blogs, Web pages and related content that do not carry the RockWealth brand identity can be owned, licensed and operated by any RockWealth Personnel. However, any and all use of RockWealth’s name, logo and/or related marks requires prior, express, written consent of RockWealth. If RockWealth is referenced in any media, all social media guidelines apply.

Scope

Generally, these guidelines set forth in this Social Media Policy should be applied to any online medium where information may reflect back on the image of RockWealth, any RockWealth Personnel and clients. This Social Media Policy applies to all forms of social media including, but not limited to: blogs, Facebook, Wikipedia or other wikis, Twitter and LinkedIn. These guidelines also apply to any comments RockWealth Personnel may leave on others’ blogs or Facebook pages, edits to wikis, responses to tweets, postings on message boards/forums, opinions on online polls or any product/services RockWealth Personnel might author.

Guidelines

1. The Internet is not anonymous, nor does it forget. Everything written on the Web can be traced back to its author one way or another and very easily. Information is backed up often and repeatedly, and posts in one forum are usually replicated in others through trackbacks and reposts or references.

2. There is no clear line between your work life and your personal life. Always be honest and respectful in both capacities. With the ease of tracing authors back from their posts and the amount of information online, finding the actual identity of a poster from a few posts and a screen name is not impossible. This creates an avenue for outside parties to link your personal writings to those you’ve done in a professional capacity. Always write as if everyone knows you. Never write anything you wouldn’t say out loud to all parties involved.

3. Avoid hazardous materials. Do not post or link to any materials that are defamatory, harassing or indecent.

4. Don’t promote other brands with our brand. Do not promote personal projects or endorse brands, causes or opinions when posting from a RockWealth account. Be sure to respect third party copyrights. If a personal opinion must be posted, clearly state to all readers that it does not represent the opinions of RockWealth.

5. Maintain confidentiality. Do not post any confidential or proprietary information in regards to RockWealth or its clients (e.g., client confidences, insider information, RockWealth’s financial information). This also means that the personal information of the employees and other individuals associated with the services that we are delivering to our clients and our own RockWealth Personnel should not be shared on or disclosed through social media.

6. Don’t pad your own stats. Do not create anonymous or pseudonym online profiles to pad link or page view stats. Also, do not comment on your own or another’s posts to create a false sense of support.

7. Always trackback. When reposting or referencing a post on one of RockWealth’s online sites, provide a link to the original post or story.

8. Identify yourself. When relevant, identify your affiliation with RockWealth and your area of concentration. This will add credibility to your profile and RockWealth’s profile/communications and will increase the visibility of RockWealth and you personally.

9. Do not pat yourself on the back. Do not post self-laudatory statements regarding your work or the work of RockWealth.

10. Do not qualify your work. Do not post statements regarding the quality of your work or the quality of the work of RockWealth.

11. Do not return fire. If a negative post or comment is found online about RockWealth or yourself, do not counter with another negative post. Instead, publicly offer to remedy the situation through positive action. Seek help from a manager or director in defusing these types of situations.

12. Do not offer or appear to offer financial advice. We should not give financial advice or otherwise form client relationships in using social media. Formation of these relationships must be done only through our regular procedures to avoid conflicts and other ethical problems.