Introduction
This policy sets out the measures adopted by Goodbody Stockbrokers to ensure the objectivity and impartiality of its investment research. It has been prepared for information purposes for the firm’s clients and other interested parties. More detailed internal policies and procedures with which all relevant staff are required to comply support this policy.Nature of Investment Research
The Institutional Equity Research department provides research coverage on most securities listed on the Irish Stock Exchange, Irish Issuers listed on other markets and other issuers which in the opinion of the Director of Research are likely to be of significant interest to our clients. The department also provides sectoral coverage relevant to issuers covered by Goodbody Stockbrokers and macroeconomic analysisLaw and Regulation
Written Institutional Research is prepared for the use of institutional investors and emailed to those clients. Research activities are carried out in accordance with all applicable laws and regulations and must not be carried out in a manner which the researcher knows or should know to be likely to put any other person at significant risk of acting in an unlawful manner or in breach of the rules or regulation applicable to that person. Researchers are expected to be aware of the laws and regulations applicable to their work and to seek advice from the Head of Research or the Compliance Department in cases of doubt. Researchers are also expected to act in a manner, which promotes high standards of ethical behaviour and professionalismIndependence
Goodbody policy is that the views expressed in research pieces must be independent and in particular must not take into account any business relationship or interest which Goodbody Stockbrokers may have or any conflicting personal interests. No person is authorised to put direct or indirect pressure on an analyst to change his opinions or the manner in which they are expressed or to take action of any type against an analyst because of the expression of views which do not coincide with Goodbody Stockbrokers.Chinese Walls Policies
The firm has formal policies relating to the maintenance and operation of Chinese Walls procedures. These procedures generally enable research coverage and trading to continue in circumstances where, in the absence of such procedures, insider dealing and market abuse legislation would prevent Goodbody Stockbrokers from trading in or covering the stock. Under no circumstances are analysts to seek to directly or indirectly obtain unpublished confidential information which is material to a listed company. Research Management has to pre-approve any request by Investment Banking staff to bring an analyst over the wall to ensure the analysts activities are managed to avoid actual or potential conflicts with other activities that the analyst may be involved in.Management and Supervision Arrangements
The Institutional Equity Research department operates as an independently managed department. All Research Analysts, report to the Head of Research. The Head of Research reports into the Director of Equities who in turn reports into the Managing Director. Analysts do not report to, and are not supervised by, personnel in any other department, including Corporate Finance The Head of Research is responsible for allocating coverage of issuers among the research team and for ensuring that appropriate arrangements are in place to clearly identify responsibility for any given piece of research and for ensuring that appropriate arrangements are in place for the preparation, review and issuance of researchRemuneration of Research Analysts
Similar to all other staff members of the firm, analysts remuneration consist of an annual salary together with bonuses based on both the firms profitability and the individual performance. Factors which may be taken into account when determining remuneration include the individuals productivity and performance, the overall quality of their research, feedback and evaluation from the firms institutional clients and sales team and the firms overall performance and profitability. No analyst is remunerated on the basis of involvement in any particular transaction or for any particular piece of workPersonal Account Dealing
Research analysts are not permitted to deal for their own account or that of their immediate family, in any securities of the companies they cover save in limited cases relating to the AIB profit sharing scheme and to holdings which existed prior to the introduction of Goodbody Stockbrokers Institutional Research policy or the date the analyst commenced coverage. Analysts holding shares in companies, which they do not cover, are subject to the firms normal staff dealing rules.Restrictive Activities
Analysts are not permitted to participate in efforts to solicit investment-banking business or attend any company or investment-banking business sponsored road shows, related to a public offering or secondary fundraising. In general where Goodbody Stockbrokers are acting in connection with an Initial Public Offering or a large secondary offering, research cannot be issued for a set period of time. Researchers will however meet companies including corporate clients separately in the normal performance of their dutiesDiscontinuation of Coverage
In the rare event that the firm discontinues coverage of a stock, (other than a delisting) it will be disclosed in the firm’s monthly book citing the rationale for such terminationDisclosures
All Institutional Equity Research publications contain required general and specific disclosures