PGR's Compliance Policies

Since PGR's inception in 2003, the investment research firm has placed strong compliance as the basis of its business, thereby protecting clients, expert consultants and employees. PGR's compliance policies are transparent, methodical and robust and are designed to ensure that every service provided by PGR and its GATE experts is fully compliant with all applicable laws, rules and regulations and poses no conflicts of interest.

Every industry and subject matter expert who consults through PGR must agree to abide by PGR's compliance policy and the Terms & Conditions set forth in our Consultant Agreement. If a client wishes specific additional compliance language to be added to communications with experts or has additional constraints on the experts that they can speak with on its projects, PGR will do so.

Experts are explicitly instructed to decline to comment on subjects that represent information that is confidential or proprietary to the organizations they are affiliated with. At no point are expert consultants permitted to breach any agreement with their employers and are required to keep in confidence proprietary information acquired by them. They are forbidden to disclose to PGR or to any of its customers or partners any material, non-public, confidential or proprietary information belonging to any previous or current employers or others.

Experts must agree to decline any consultation that presents a conflict of interest or a perceived conflict of interest. If, during the course of any consultation they believe that any of PGR's clients seek to cause them to violate this agreement, they must immediately cease the consultation and inform PGR of such potential violation.

Experts must certify that they are not a Director of a publicly traded company: neither a member of the board nor an officer of any company, the securities of which are publicly traded.

Experts must keep all consultations with PGR's customers confidential and treat them as the sole property of PGR.

Each expert bears responsibility for determining whether he or she is permitted to accept a consultation under the Terms & Conditions. If an expert must receive permission from his or her employer, it is the expert's responsibility to obtain that permission prior to accepting a consultation request. The decision of whether to accept a particular request is always the expert's alone.

Additionally, PGR maintains and enforces a global "Do Not Consult" list of companies that do not permit their employees to consult through third party providers like PGR. The list is compiled from companies that have contacted PGR directly.

PGR also provides its clients with customized tools to meet their compliance responsibilities. Clients may provide PGR with lists of companies whose employees they do not wish to speak with, such as companies in which clients hold or are considering investments. Clients may designate that they not be presented with experts who work for publicly traded companies.

For a more detailed description of the Compliance Procedures at PGR, please email info@pg-research.com.