SMARTKARMA INSIGHT PROVIDER

Code of Conduct

As a professional independent research provider, you have the potential to influence investors and affect their returns. This power carries with it significant responsibilities. Smartkarma requires its Insight Providers to agree to the Smartkarma Code of Conduct. This code serves as a guide to making consistent, responsible, ethical and legal choices in all of your research.

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Smartkarma Insight Provider Code of Conduct

1

I am honest

My actions bring respect for and trust in my research.
2

I obey laws and public policies

if I violate any law or public policy, I act promptly to correct the situation.
3

I protect confidential information

while acting within the law.
4

I support the ideals of free speech

freedom of assembly, and access to an open marketplace of ideas.
5

I am sensitive to others’

cultural values and beliefs. I will not be overly aggressive and I do not believe that vulgarity has a place in investment research.
6

I give credit to others

for their work and cite my sources.
7

I do not use confidential information

for personal benefit.
8

I present my opinion as my opinion

My opinion and interpretation of events is important and should be shared but must never be confused with hard facts or data. When voicing your own or someone else’s opinion or interpretation, always state it as such. Never present opinion, interpretation or conjecture as fact.
9

I state my allegiances to stay independent

To preserve my own trustworthiness and integrity as a Content Creator, I always state any relation, financial, personal, political or otherwise, to the subject or topic I am presenting. Bias, even if it is only perceived as such, immediately discredits my account unless I warn of it first. In simple terms; if I have a political affiliation that colours my judgment, I will say so; if I am employed by or received money from the subject I am covering, I will say so; if I was given gifts or preferential treatment in return for a positive review or commentary, I will say so. By stating these facts of allegiance my opinions gain informational value that would otherwise be lost in suspicion of bias.
10

I admit and correct my mistakes immediately

When an inaccuracy or error in my content is discovered by myself or someone else, I correct it immediately and announce that I have done so to ensure that those who base their opinions and other content creation on the incorrect information have a chance to make corrections as well. It is my duty to uphold the truth and present fact even if that means admitting I was wrong.
11

I will not write research where my experience is not relevant

My content will be relevant to my experience and I will state my experience in an area if it is not readily apparent.
12

I will write research with the express aim of adding value to the end reader

Where the value is not immediately apparent I will be explicit about the value being added.
13

I will not try to indoctrinate my readers or offer up polemics

When I discuss politics, religion or mindsets I will be balanced in my approach and refrain from the suppression of all other viewpoints.

Code of Conduct in Practice

Smartkarma requires its Insight Providers to embrace these guidelines in their work and to sign the following statement as part of the application and renewal processes: “I have reviewed and understand the Smartkarma Code of Conduct.”

The association reserves the right to terminate membership for any member found to have violated the code.  Any violation will be subject to a ‘3 strikes’ ruling. Meaning that if any Insight Provider is found to breach the code on three separate occasions their access to the Smartkarma platform will be terminated.

Alleged breaches of the Code of Conduct will be considered by the Conduct Committee and notifications of findings will be sent out to the Insight Provider and published on the Smartkarma website.

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