LodeRock Research Principles and Policies

Much like credit rating agencies, LodeRock’s fee-based research is governed by policies designed to assure quality, integrity and objectivity in the analytical process.

1. Core principles

• The foundation of LodeRock Research’s product and brand are credibility, insight and impact.
• The value of an equity research product is a function of its independence. The key principal for LodeRock Research has built a reputation of trust with global investors for over 25 years.
• LodeRock is committed to providing a product of the highest quality, focusing on rigor in the financial estimate and valuation analysis process and providing a well-thought-out investment thesis.
• LodeRock seeks to be impactful to the investment process by concentrating research on the most important investment drivers. Our policy is to publish whenever an event is impactful to the investment thesis and/or changes are warranted to estimates or valuation assumptions.

2. Conflict of Interest and Ethics Management

• LodeRock has no sales, trading or investment banking business
• LodeRock Research clients have no editorial rights on the product
• LodeRock analysts are members of, and/or are bound by the ethical standards of, the CFA Institute
• In the event that research is discontinued on a stock, LodeRock Research will publish a final report with estimates making this clear
• The head of LodeRock Research has primary responsibility for regulatory compliance