Code of Ethics

Cleary Gull Advisors has adopted a Code of Ethics to assist employees in carrying out its duties as a fiduciary to its clients. The Code of Ethics is based upon the principle that Cleary Gull Advisors and its employees owe a fiduciary duty to clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid: (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the firm, and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. The Code of Ethics is designed to maintain Cleary Gull Advisors’ high ethical standards. Existing or prospective clients may contact Cleary Gull Advisors for a full copy of the Code of Ethics.

Privacy Policy

This Privacy Policy applies to the following Johnson Financial Group affiliates: Johnson Bank, Johnson Insurance Services, LLC, and Cleary Gull Advisors Inc. In this notice, each of the companies that make up Johnson Financial Group, Inc. is referred to as “we,” “our,” or “us.”

This notice is intended to describe how we collect, maintain, disclose and dispose of customer information. This notice may be amended from time to time at our discretion. If you have questions, comments or complaints about the privacy of information about you, please contact: Johnson Financial Group, 555 Main Street, Suite 060, Racine, WI 53403, 888.769.3796, This is not a secure email facility.

Gathering of Information and Use

We collect nonpublic personal information about you from the following sources:

• Information we receive from you on account applications or other forms;
• Information about your transactions with us, our affiliates, or others; and
• Information we receive from a consumer reporting agency.

We may disclose all of the information we collect, as described above, about you or our former customers to Johnson Financial Group affiliates that are insured depository institutions, insurers, and providers of investment, and trust services.

Except for information related to fiduciary trust relationships, we may disclose all of the information we collect, as described above, about you or our former customers to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements.

We may also disclose all of the information we collect as described above, about you or our former customers to others outside of Johnson Financial Group, as permitted by law.

Your Right to Opt Out of Having Certain Information Shared With Our Affiliates

NOTE: This section of our Privacy Policy applies to you if you are an individual who seeks to obtain, obtains or has obtained a financial product or service from us primarily for personal, family, or household purposes. This section of our Privacy Policy does not apply to individuals who seek to obtain, obtains or have obtained financial products or services from us for primarily business purposes, and does not apply to any of our corporate customers.

The Fair Credit Reporting Act permits you to direct us not to share certain information among the Johnson Financial Group affiliates. Specifically, you can tell us not to share information that is unrelated to your transactions or experiences with us. This may include information you have provided to us or information we obtain from unrelated third parties to determine your eligibility for products (for example, credit bureau reports). To notify us not to share this information you must contact us in writing with your name, Social Security Number, address, and account type and number. Your notice should be mailed to: Johnson Financial Group, Fair Credit Reporting Act Notice, 555 Main Street, Suite 060, Racine, WI 53403.

If you have previously provided us with a notice not to share information, you do not have to provide it to us again.

Confidentiality and Security

We restrict access to nonpublic personal information about you to those employees who need to know that
information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal banking/financial services regulations to guard your nonpublic personal information.

Maintaining Accurate Information

We strive to maintain complete, accurate and current information on our customers. If you believe any information in your customer records with us is insufficient, inaccurate, or out of date, please contact us as provided in the introductory section of this notice.

Business Practice

Customer Identification 

To help the government fight the funding of terrorism and money laundering activities, and to assist certain custodians in opening accounts, Cleary Gull Advisors may obtain, verify, and maintain information that identifies each entity or person who becomes a client. We may ask for your name, address, date of birth (for an individual), and an identification number or articles of incorporation that will allow us to verify your identity. We may also ask for a driver’s license or other identifying documents. This process may include the use of third party sources to verify the information provided.

For accounts owned by a trust, customer identification procedures may require Cleary Gull Advisors to obtain a copy of a trust instrument. Any trust instrument will be retained solely for the purposes of customer identification, and Cleary Gull Advisors accepts no responsibility for the enforcement or administration of any of the terms thereof.

Business Continuity Planning

In accordance with regulations, Cleary Gull Advisors participates in Johnson Financial Group’s business continuity plan that is intended to permit us to continue, or quickly recover and resume, critical business operations during natural disasters, power outages, or other significant events. While there can be no assurance that service will continue without interruption in all circumstances, our plan does address the actions that we will take in the event that there is a significant business disruption.

Our plan addresses:

  • Data backup and recovery
  • Mission critical systems
  • Financial and operational assessments
  • Alternative communications with customers, employees and regulators
  • Alternate physical location of employees
  • Critical supplier, contractor, bank and counter-party impact
  • Regulator reporting
  • Assuring clients prompt access to their funds and securities if we are unable to continue our business
  • Any entities the firm may rely on for certain procedures and/or mission critical systems

Because our plan contains details of a confidential and proprietary nature, it is not distributed to the public.

Contacting Us: In the event of a significant business disruption, you can obtain up-to-date information regarding the operating status of our firm on this website. In the event you cannot contact us or obtain up-to-date information from this website, you should contact your account custodian who will assist you in accessing your funds and securities and/or processing account transactions.

Terms of Use

Important Legal Information*

By using this site, you signify your assent to, and agree to be bound by, the following terms and conditions. You should read these conditions carefully before using this site, and if you do not agree to these terms, you should exit this site. These terms may be amended at any time. Cleary Gull Advisors provides this site for informational purposes. Nothing on this site should be construed as an offer or solicitation to buy or sell any securities, futures, options or other financial instruments or provide any investment advice or service.

Disclaimer of Warranty and Limitation of Liability

The information on this site is provided “as is”. Cleary Gull Advisors does not warrant the accuracy of the materials provided herein, either expressly or by implication, for any particular purpose and expressly disclaims any warranties of merchantability or fitness for a particular purpose. Cleary Gull Advisors will not be responsible for any loss or damage that could result from interception by third parties of any information made available to you via this site.

Although the information provided to you on this site is obtained or compiled from sources we believe to be reliable, Cleary Gull Advisors cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose.

Neither Cleary Gull Advisors, nor any of its affiliates, directors, officers or employees, nor any third party vendor will be liable or have any responsibility of any kind for any loss or damage, of any kind or nature, that you incur in the event of any failure or interruption of this site, or resulting from the act or omission of any other party involved in making this site or the data contained therein available to you, or from any other cause relating to your access to, inability to access, or use of the site or such data, whether or not the circumstances giving rise to such cause may have been within the control of Cleary Gull Advisors or of any vendor providing software or services support. In no event will Cleary Gull Advisors, its affiliates or any such parties be liable to you for any direct, special, indirect, consequential, incidental damages or any other damages of any kind even if Cleary Gull Advisors or any other party have been advised of the possibility thereof.

Use of Content

Cleary Gull Advisors owns this website, and permission is given to display and navigate this site for personal use only. You may download material displayed on this site for non-commercial, personal use only, provided you also retain all copyright and other proprietary notices contained on the materials.

Use of Links

If you leave this site via a link contained herein, you do so at your own risk. The content to which you link will not have been developed, checked for accuracy, or otherwise reviewed by Cleary Gull Advisors. Cleary Gull Advisors is not responsible for damages or losses caused by privacy practices or any delays, defects or omissions that may exist in the services, information or other content provided in such site, whether actual, alleged, consequential or punitive. Cleary Gull Advisors makes no guarantees or representations as to, and shall have no liability for, any electronic content delivered by any third party, including, without limitation, the accuracy, subject matter, quality or timeliness of any electronic content.

Procedure for Making Claims of Copyright Infringement

Cleary Gull Advisors respects the intellectual property of others and asks that you do the same. If you believe that your copyrighted work is accessible on this site in a way that constitutes copyright infringement, you may notify us by providing our Copyright Agent with the following information: 1) the electronic or physical signature of the owner of the copyright or of the person authorized to act on the owner’s behalf; 2) a description of the copyrighted work that has allegedly been infringed; 3) identification of the specific location on this site where that work is located; 5) your name, address, telephone number, and email address; 6) a statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner’s behalf. The agent of Cleary Gull Advisors for claims of copyright infringement on this site is

Materials on this website dated prior to June 1, 2016 may relate to, or may have been created by, employees of the investment management division of Cleary Gull Inc., which was acquired by Cleary Gull Advisors Inc.

Governing Law

These Terms of Use shall be governed by and construed in accordance with the laws of Wisconsin, without giving effect to any principles of conflicts of law. If you take legal action arising out of or relating to these terms and conditions, you agree to file such action only in the state or federal courts, and you hereby consent and submit to the personal jurisdiction of such courts for the purposes of litigating any such action*. If any provision of these terms is deemed unlawful, void, or for any reason unenforceable, then that provision shall be deemed severable from these terms and shall not affect the validity and enforceability of any remaining provisions. This is the entire agreement between Cleary Gull Advisors and the user relating to the subject matter herein.

Cleary Gull Advisors Inc.
100 East Wisconsin Avenue
Suite 2400
Milwaukee, WI 53202

Form ADV

*Cleary Gull does not provide legal or tax advice.