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Policy

Conflict of Interest Policy.

Disclosure rules that keep coverage independent.

Placeholder — Final Text Pending

Conflict of Interest Policy

This page is a structural placeholder. The final policy will be inserted before launch. Consistent with our Research Standards, it will require disclosure of any position, relationship, or financial interest that could reasonably be seen as influencing a conclusion — and it will restate the rule that coverage is never for sale, positive or negative.

  • §1 — Personal trading restrictions for coverage subjects
  • §2 — Client relationships and independence of published research
  • §3 — Disclosure format in published reports
  • §4 — Prohibition on pay-to-praise engagements
  • §5 — Annual attestation and enforcement