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
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
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