EFFECTIVE DATE: October 4, 2017

Conflicts of Interest Policy

Digital Asset Research ("the Firm" or "DAR") takes possible conflicts of interest or the appearance of conflicts of interest very seriously and will not engage in, or otherwise tolerate, any conduct that raises questions about the independence and impartiality of its research. It has adopted this Conflicts of Interest Policy (the “Policy”) as part of its Conflicts Compliance Program to assist the Firm in identifying and managing potential conflicts of interest that may affect or raise questions about its independence and impartiality. This policy is made available on the DAR website at https://www.digitalassetresearch.com/conflict-of-interest-policy/. DAR reserves the right to amend or supplement this policy at any time.

 

I.            Responsibilities of Firm Employees

 

1.      All Firm employees are required to undergo annual testing and training to ensure they are familiar with their role and responsibilities under this Policy, as well as any other policies and procedures that the Firm may implement from time to time to manage any possible conflicts of interest or perception thereof. Such training includes training related to Section I.2.

2.      Upon learning about an actual conflict of interest or any event or circumstance that in the reasonable discretion of the Firm employee would lead an unbiased outside observer to question the independence and impartiality of DAR, such employee must submit a Potential Conflicts Report in accordance with the Firm’s procedures. DAR prohibits retaliation against anyone who, in good faith, reports suspected misconduct.

 

II.            ACTIVITIES OF FIRM EMPLOYEES

1.      All activities of Firm employees must be in accordance with the Business Courtesies Policy. Firm employees may neither give nor receive anything of value unless it is free from the perception that favorable treatment is being sought, received, or given in exchange for such thing of value.

2.      DAR restricts its employees from performing roles that could prejudice, or appear to prejudice, the independence of their research. As a rule, but subject to Section VI.4, Firm employees, while employed, are prohibited from receiving compensation, equity, or other remuneration from a token project, whether from such project’s foundation, development firm, or other related entity. This includes but is not limited to serving as a board member, advisor, or consultant.

3.      Within 24 hours of being offered any Business Courtesy or remuneration whereby acceptance of such is reasonably likely to result in a violation of Section II.1 or II.2, Firm employees must submit a Potential Conflicts Report.

4.      Firm employees are permitted to trade tokens on which they issue research and this is disclosed in DAR’s reports (See Section III. Disclosures). Firm employees must update the Firm’s Employee Holdings List within 24 hours of adding or removing a token from their portfolios.

 

III.            Disclosures

1.      The Firm discloses conflicts of interest in its reports, including those of the Firm and the employee that are or may be material in the context of the relevant report.

2.      The “Disclosures Section” of each report divulges any such conflicts, including whether any employee who contributed to the report has holdings of the token that is the subject of the report.

 

IV.            Compensation of Firm Employees

1.      The evaluation and appraisal of Firm employees for purposes of career advancement, compensation and promotion may not be directly linked to specific transactions or the profitability of specific research projects, but will in part reflect the overall profitability of the Firm.

2.      The compensation of Firm employees is based on several factors, including quality, accuracy and value of research, productivity, experience, individual reputation, and evaluations by clients and by other Firm personnel.

 

V.            Review and Comment on Research

1.      DAR policies and procedures are designed to ensure that parties with interests that may potentially conflict with those of recipients of research are not able to review or comment on research in a manner that might affect the impartiality of the research.

2.      Prior to publication, all research reports are reviewed by a supervisory analyst. The purpose of these reviews is to confirm compliance with the Firm's policies and procedures, including the requirement that research be clear, fair and not misleading.

3.      Firm employees may check the accuracy of factual statements with any token issuer that is the subject of their research. DAR policies require such employees to submit a Potential Conflicts Report that records the reasons for any subsequent material change made to a research report after factual matters have been reviewed by issuers or other personnel with potential conflicts of interest.

 

VI.            MISCELLANEOUS

1.      Failure of Firm employees to adhere to the requirements of DAR policies may result in a range of sanctions, up to and including termination of employment. 

2.      This Policy is not intended to create third party rights or duties that would not already exist if the policy had not been made available, or to constitute or form part of any contract between the Firm and any client or customer of the Firm (or any other person).

3.      This policy may be supplemented by more detailed policies and procedures adopted by the Firm from time to time.

4.      Variations and exceptions to this policy may be approved by the Board of Directors in individual cases, with the goal of promoting the objectives of this Policy in all circumstances.