Code of Conduct

Honesty and Good Faith

Research analysts must act with honesty and good faith at all times.

Responsibility of Management

Senior management is primarily responsible for upholding high standards of conduct and ensuring adherence to proper procedures within the research analyst's operations.

Conflict of Interest

Research analysts must effectively manage any conflicts of interest that could impact the impartiality of their analysis and reports. They must also provide appropriate disclosures to address these conflicts.

Insider Trading and Front Running

Research analysts and their employees are prohibited from engaging in insider trading or front running, including the exploitation of their own research reports.

Compliance

Research analysts must comply with all applicable regulatory requirements related to their business activities.

Confidentiality

Research analysts and their employees must maintain the confidentiality of reports until they are publicly released.

Professional Standards

Research analysts and their employees should adhere to high professional standards in the preparation of research reports.

Diligence

Research analysts must act with due skill, care, and diligence, ensuring that research reports are prepared following thorough analysis.