Research Policy

Research Policy

Introduction

Algosun Global Limited is a provider of equity research, consulting, and market analysis services. Algosun Global Limited is not a registered broker-dealer or an investment adviser with Cyprus Securities and Exchange Commission (hereinafter “CySec”) or with any state securities regulatory authority. Algosun Global Limited is free of any conflict of interest from investment banking or trading pressure on research content and stock ratings.

This document aims to outline the systems, procedures, and controls in place at Algosun Global Limited to manage conflicts of interest in connection with its independent equity research. The Policy applies to the production and distribution of research by Algosun Global Limited, and this Policy applies to independent equity research. The procedures set out within this Policy are designed to maintain the independence of such research.

Equity Research Production Controls

The relevant regulatory rules require that Algosun Global Limited implement controls to ensure that equity research is produced and distributed controlled and that all relevant conflicts of interest have been identified and, where possible, mitigated.

Organization and Responsibilities

Each Research Group is headed by a Head of the Group responsible solely for equity or quantitative research. He/she reports directly to Directors.

Equity analysts and quantitative researchers must not become involved in other parts of business activities within Algosun Global Limited other than the research and preparation of equity and quantitative research.

This does not preclude involvement in prospect phone calls where the analysts and researchers explain their areas of expertise. However, analysts, researchers, and other employees must only provide actual or prospective clients with research opinions, specific advice, or recommendations after the release of any equity research report. All personnel, including analysts, must declare all outside business interests to keep Algosun Global Limited informed of any apparent appearance of or actual conflicts of interest. To ensure equity research is distributed to clients simultaneously and in a controlled and coordinated manner, analysts and researchers may not disclose the likely timing or content of equity research to any non-research personnel except for the Director of Research. The Director of Research and Editor-in-Chief who submit research for publication must declare that neither the views expressed in nor the timing of the research publication have been influenced by knowledge, if any, of client position(s) in the research security or securities.

The Director of Research may discuss his published views on the sector and other companies. This may include approaches to valuation, multiples, stock ratings, and spreads for the sector and peer group companies and hypothetical valuations, multiples, ratings, and spreads derived from them.

Research Standards

The Director of Research is the firm’s designated Compliance Officer. Equity analysts and quantitative researchers directly report to the Director of Research and do not communicate with clients. The Director of Research makes decisions on research reports' coverage, content, and timing. Before official publication and distribution, the final research report draft should be double-checked and reviewed by an Editor-in-Chief.

All research requires the Director of Research's approval before publication. Analysts and researchers do not participate in Sales Pitches and Presentations. No part of the analyst’s and researcher’s remuneration is related directly or indirectly to the views expressed in the research reports. Analysts and researchers are not permitted to accept any remuneration or other benefit from any party in respect of the publication of research. Analysts and researchers may not serve as officers, directors, employees, or advisors to a company under research coverage. Algosun Global Limited maintains a database of clients to whom it emails its research reports.

Moreover, Algosun Global Limited applies the following standards in the presentation of its stock ratings:

• All research communications differentiate between factual information and interpretations, estimates, opinions, or other non-factual information.
• Algosun Global Limited will quote only reliable resources – if there is any concern regarding the reliability of a source, then this will be indicated.
• All projections, forecasts, and price targets are clearly labeled as such, and any material assumptions made in producing or using them are indicated.
• The substance of any stock ratings shall be capable of scrutiny and substantiation.
• All substantially material sources of information are clearly and prominently indicated.
• Any valuations and methodologies used to evaluate a company's security or set price targets shall be adequately summarized.
• If the stock rating differs from an earlier rating issued during the preceding 12-month period, the change and the date of the earlier stock rating shall be indicated clearly and prominently.

Stock Ratings

Algosun Global Limited uses a relative rating system using terms such as Overweight, Equal-weight, Underweight, and Suspended. Algosun Global Limited does not assign ratings of Buy, Hold, or Sell to the stocks we cover. Overweight, Equal-weight, and Underweight are not the equivalent of Buy, Hold, and Sell. Investors should carefully read the definitions of all stock ratings used in Algosun Global Limited Research. In addition, since Algosun Global Limited Research contains complete information concerning the analyst’s views, investors should carefully read Algosun Global Limited Research in its entirety and not infer the contents from the rating alone. In any case, ratings should not be used or relied upon as investment advice. An investor’s decision to buy or sell a stock should depend on individual circumstances and other considerations, and Algosun Global Limited does not provide individually tailored investment advice.

Overweight (OW). Expected to appreciate, produce a total return of at least 10%, and outperform the coverage group’s historical fundamentals and/or valuations on a risk-adjusted basis over the next 6 to 12 months.

Equal-weight (EW). Expected to generally perform in line with the coverage group’s historical fundamentals and/or valuations on a risk-adjusted basis over the next 6 to 12 months.

Underweight (UW). Expected to underperform, produce a total return below the average of the coverage group’s historical fundamentals and/or valuations on a risk-adjusted basis over the next 6 to 12 months.

Suspended (S). The rating and price target have been suspended. This action may be due to market events that made coverage impracticable. If research coverage is terminated and Algosun Global Limited has published forecasts and reports, the firm publishes a final note stating that coverage has been terminated.

Algosun Global Limited is not involved in sponsored research, namely equity research sponsored by companies under research coverage.

Research Confidentiality

Equity analysts, quant researchers, and any other in-house or outsourced employees must maintain client confidentiality and ensure any knowledge of the timing or content of equity research is not divulged to any third party other than those identified in current contractual arrangements with the firm.

Dealing Ahead of the Distribution of Research

Equity analysts and quant researchers must not undertake any personal account dealing in any stocks covered in equity research of Algosun Global Limited and/or included in the Restricted List maintained by Algosun Global Limited. The firm must not act on any research advice for its benefit, where the client's interests are always prioritized.

Inducements

Analysts, researchers, and any other employees involved in the production of equity research must not accept inducements from those interested in equity research. Small gifts or minor hospitality are not deemed inducements; however, analysts and researchers are not permitted to accept inducements above the level set out in the firm’s Internal Gifts Policy. All gifts must be notified to Compliance Officer using the appropriate form.

Independence

The firm, analysts, quant researchers, and any other employees involved in producing equity research must not promise favorable research coverage to those entities on which it prepares stock ratings or to any other person or entity. The firm maintains a list of those permitted to produce and review equity research before and after publication.

Editing

Only the specified equity analysts and quant researchers responsible for producing equity research and the Director of Research on a particular company may review draft research ahead of issuance. Equity research revisions are subject to rigorous change control by the manager selection team comprised of analysts, researchers, and heads of groups. Only the Director of Research of the firm may comment on the stock ratings made by the firm, and prior approval will not be requested from other groups or third parties before distribution. However, the Compliance Officer may also review research before distribution. Editorial control over draft research will not be given to any subject company, or any other party whose role or commercial interests could provide an apparent appearance of or actual conflict with the interests of Algosun Global Limited clients. However, draft research may be submitted to the subject company ahead of publication for the sole purpose of checking facts.

Remuneration of Analysts and Researchers

Analysts and researchers do not participate in activities ancillary to research products and are paid accordingly. Analysts’ and quant researchers’ performance-related pay is based solely on the accuracy and quality of their stock ratings and not on the performance of groups other than the firm.

Personal Account Dealing Policy

Analysts, quant researchers, and connected persons are prohibited from dealing in securities of public companies under research coverage or connected companies for whom Algosun Global Limited conducts and distributes independent equity research.

Equity Research - Means and Timing of Publication

The firm has implemented a series of controls to ensure equity research is distributed in a controlled manner as follows:

• Equity research may only be distributed to authorized clients or relevant entities approved by the firm.
• Equity research must be distributed in a coordinated manner designed to ensure clients have access to the information simultaneously using agreed distribution channels.
• Research is distributed in electronic format, and the firm strives to ensure all research is distributed to clients simultaneously.
• Analysts and quant researchers are expected to consider the research subject’s circumstances before the release of any new research which might have a significant bearing on the timing of the release (such as an offering by the research subject).

Equity Research Confidentiality

The firm has implemented security controls designed to ensure equity research is only available to those permitted to view the research. Controls include:

• The firm systems are password protected.
• All system users receive a user profile, which restricts access to the system determined by their job function.
• Client access is restricted to equity research they have contracted to purchase and/or that the firm has approved and agreed to provide.

Stock Ratings: Required Disclosures

Algosun Global Limited has implemented relevant regulatory disclosures required when making “stock ratings”, a defined term. Note that there are separate definitions for “stock rating”.

The firm must take reasonable care to ensure that stock ratings produced or assigned by it are fairly presented. The firm’s equity research and presentations are produced according to a standard template protected by copyright to comply with the relevant rules and standards, including the independent research requirements. Research is published in a non-editable format to ensure the integrity of equity research. All equity research must be clearly labeled “equity research” where it satisfies the relevant regulatory definitions.