ACG ANALYTICS, INC.’S POLICY AND PROCEDURES TO ENSURE AVOIDANCE OF COLLECTION, RECEIPT AND/OR DISSEMINATION OF MATERIAL NON-PUBLIC OR OTHER RELEVANT CONFIDENTIAL INFORMATION…
ACG Analytics, Inc. (ACGA) provides unbiased, objective research and information to institutional investors about public policy in the legislative, regulatory, and judicial spheres primarily in and around Washington DC based upon ACGA’s proprietary “mosaic research” methods.
ACGA is affiliated with American Continental Group, Inc., an advocacy and government relations firm. ACGA does not provide research or analysis on any specific client of American Continental Group, Inc.
ACGA understands that as part of its respective clients’ daily business, ACGA’s clients buy and sell securities. ACGA does not recommend individual investments and does not conduct detailed security analysis. The decision to sell or purchase a security rests solely with the client.
ACGA does not seek to acquire material non-public information of any kind in the course of its policy research activities and only conducts its ongoing policy research efforts in accordance with all relevant laws, regulations and policies, including, but not limited to, applicable federal and state securities laws and regulations.
ACGA discloses to persons it contacts in connection with its research that ACGA has been engaged by an investment firm that buys and sells securities to assist it in its analysis and that ACGA is not seeking, and does not want to receive, any confidential information. ACGA does not seek to obtain any information from a government employee where disclosure of any such information by the government employee would violate any law, regulation or policy.
ACGA does not disseminate nor permit the dissemination by any of its employees, officers, principals or agents, of any non-public information regarding any company, or any other disclosure in violation of law or regulation or any contractual or other duty or obligation of any nature.
ACGA safeguards proprietary information received from clients and will ensure that such proprietary information is not shared with any unauthorized parties, including, but not limited to, other ACGA clients.
If ACGA becomes aware of any improper disclosure to any of its clients or any of their respective employees or agents by any employee, agent, or principal of ACGA, it will notify such client in writing as soon as reasonably practicable, and will describe with reasonable specificity the nature of the disclosure, and will use commercially reasonable efforts to cooperate with such client in any investigation of, or action against (or threatened against), such client and its employees, including portfolio or account managers of such client, or any of its affiliates relating to or arising out of such disclosure.
ACGA employees will participate in mandatory periodic training sessions with regulatory counsel to ensure compliance with this policy and the associated procedures described herein. ACGA employees will also re-affirm in writing on an annual basis their understanding and compliance with this policy and acknowledge that they and ACGA could be subject to disciplinary action, including termination, and/or legal liability for any violation thereof.