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Winterbotham’s policy requires that we apply compliance procedures in accordance to Know-Your-Client rules and regulations. However, since inception, Winterbotham has always operated under strict “know your customer” policies imposed both internally and by our regulators. We have interpreted such policies literally and always invested significantly in meeting with principals personally prior to contract to learn about their background and business and thus to better enable the design and innovation of relevant services. Similarly, we believe in the personal delivery of our service as a means of enhancing value and assuring that the desired results are attained.

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