Clients.

Compliance

Connecting professional decision-makers who seek specialized expertise with those industry participants who possess it helps improve the allocation of scarce economic resources and accelerates global business innovation. That said, any information exchange must occur within a rigorous compliance framework that safeguards the legal rights and obligations of both parties.

AlphaSights has invested significant resources into developing a compliance framework of rules, practices and systems intended to help both parties safeguard their interests and obligations at all times.

The AlphaSights Compliance Framework comprises the following components:

Awareness

• Prior to any consultation, Clients and industry specialists (“Advisors”) are specifically made aware of the limitations to the type of information that can be solicited or disclosed, in particular with respect to material, non-public information relating to publicly listed companies.
• Both Clients and Advisors need to confirm their awareness electronically in writing.

Confidentiality

• Advisors need to sign our Terms and Conditions contract prior to participating in any consultation, requiring them to never disclose confidential information to clients and to maintain client information as confidential.
• AlphaSights’ Client Service and Research Teams are trained to deal with the confidentiality of our clients’ information and the participation of our Advisors. In addition, they operate under “need-to-know” restrictions to further safeguard sensitive information.

Conflict avoidance

AlphaSights has developed and continues to expand a system of contractual rules and restrictions - supported by corresponding systems and workflows - that govern and restrict the type of participants and subjects of consultations arranged by AlphaSights. These rules and restrictions include, among others, the following:

• Employees are without exception not permitted to participate in any consultation regarding their employer. In addition, employees must verify electronically that they are not prohibited by any contractual obligation from consulting with third parties in general or regarding the proposed subject matter in particular.
• Employees in full-time employment wishing to enrol in the Executive Advisor Program require their employer’s or partner-level written consent.
• Employees of publicly listed companies can, at clients’ discretion, be excluded categorically from any short list of potential consultation partners.
• Employers may register with AlphaSights any specific guidelines or restrictions that govern their employees’ interactions with third parties. Any such restrictions are stored in AlphaSights systems and automatically apply to all employees concerned.
• Finance professionals including external auditors may not discuss financial or accounting aspects of companies for which they have worked within the last 6 months or which they have audited within the last 2 years.
• Franchisees may discuss aspects of their own franchises, but not any data, plans or other aspects relating to their franchisor.
• Intelligence Limitations exist to prevent AlphaSights’ services to be used by clients to obtain information on competitors.
• Physicians participating in clinical trials may not discuss patient experience or trial results not yet in the public domain.
• Public Officials may not on a paid basis discuss government legislation, regulation, policy, contracts, or other business that such public official is in a position to influence.
• Sales Personnel at retailers or distributors selling third-party products and services may discuss products and sales trends relating to third-party products, but not their own company's specific performance.

Risks and responsibilities

Both Advisors and Clients are made aware of the legal risks associated with soliciting and disclosing material non-public information, and of their responsibility for conducting themselves ethically and in accordance with applicable laws and regulations at all times.