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Compliance

This page details our compliance policy.

1. Subscription Tiers

Convequity continues to offer distinct subscription tiers to cater to varying client needs:

  • Entry Tier:
    • Access: Subscribers have access to articles specifically tagged with "entry."
    • Ideal For: Individuals or organizations seeking foundational insights and introductory content.
  • Premium Tier:
    • Access: Subscribers enjoy unrestricted access to all content available on Convequity.com, including exclusive research reports, in-depth analyses, and comprehensive resources.
    • Ideal For: Clients requiring extensive research materials and advanced analytical tools.

2. Research Distribution

  • Simultaneous Distribution:
    • All research reports are disseminated to all clients in the same tier simultaneously, ensuring that every subscriber receives the latest information without delay.
  • Tier-Based Access:
    • Clients subscribed to the same tier receive access to research materials concurrently. This structured approach guarantees uniformity in information dissemination and maintains the integrity of our subscription offerings.

3. Compliance Framework

Ensuring adherence to regulatory standards and maintaining the highest ethical standards is paramount to Convequity. Our compliance framework encompasses the following key areas:

a. Research Review

  • Objective Evaluation:
    • Every research report undergoes a stringent review process to ensure accuracy, relevance, and compliance with industry standards.
  • Quality Assurance:
    • Before the content release, we meticulously assesses each publication, verifying data integrity and methodological soundness before release.
  • Regular Audits:
    • Periodic audits and reviews are conducted to evaluate the effectiveness of our research review procedures, facilitating continuous improvement.

b. Compliance Training

  • Comprehensive Programs:
    • We implement ongoing compliance training programs for all employees, emphasizing the importance of regulatory adherence and ethical conduct.
  • Assessment and Certification:
    • Regular assessments are administered to gauge understanding, reinforcing accountability.

c. Compliance Documentation

  • Robust Documentation Practices:
    • Compliance-related activities are thoroughly documented to maintain transparency and traceability.
  • Accessible Records:
    • Documentation is systematically organized and readily accessible to authorized personnel, facilitating efficient compliance monitoring and reporting.
    • We use Lark Suite (SOC 2 & ISO27001 certified) with RBAC to enforce proper access control and security measures. Every internal message and documentation is recorded and backed up in AWS in real-time.
    • We distribute content via Ghost.io managed service.
  • Regulatory Alignment:
    • Our documentation processes are aligned with current regulatory requirements, ensuring that Convequity remains compliant with all applicable laws and standards.

Compliance Training Process

Convequity is dedicated to fostering a culture of compliance and ethical behavior. Recognizing our boutique size and limited resources, our training approach is streamlined to deliver essential compliance knowledge efficiently and effectively to all employees.

a. Training Programs

  • Onboarding Training
    • Essential Compliance Orientation: New employees receive a focused compliance training session during their initial orientation. This covers key policies, ethical standards, and fundamental regulatory requirements to ensure they understand their responsibilities from day one.
  • Ongoing Education
    • Periodic Compliance Updates: Instead of extensive regular training sessions, employees are provided with concise updates on relevant regulatory changes and best practices through monthly newsletters or brief internal memos.
    • Annual Refresher: An annual mandatory refresher module reinforces critical compliance principles and updates employees on any significant policy changes.

b. Delivery Methods

  • Virtual Q&A Sessions
    • Interactive Support: Periodic virtual sessions are hosted by the compliance officer to address any questions or concerns employees may have. These sessions provide an opportunity for real-time clarification and reinforce a supportive compliance environment.

c. Continuous Improvement

  • Feedback Mechanism
    • Employee Input: Regular feedback is solicited from employees regarding the effectiveness of training materials and delivery methods. This input helps in refining and enhancing the training program to better meet the team’s needs.
  • Policy Updates
    • Dynamic Content: Compliance policies and training materials are regularly reviewed and updated to reflect the latest regulatory changes and industry best practices, ensuring that all training content remains current and relevant.

Compliance Documentation

Effective compliance documentation is essential to Convequity’s operations, ensuring transparency and adherence to regulatory standards. Our documentation practices are streamlined to suit our size while maintaining robustness.

a. Documentation Practices

  • Comprehensive Records: We keep detailed records of all compliance activities, including training sessions, audit results, and policy updates.
  • Policy Management: All company policies and procedures are stored in a centralized repository with version control to track updates and changes.

b. Accessibility and Security

  • Secure Storage: Compliance documents are securely stored and backed up regularly to protect against unauthorized access and data loss.
  • Controlled Access: Access to sensitive documents is restricted based on employee roles, ensuring that only authorized personnel can view or modify them.

c. Regulatory Alignment

  • Compliance with Standards: Our documentation meets all relevant legal and regulatory requirements, ensuring that Convequity remains compliant with applicable laws.
  • Regular Updates: We promptly update our documentation in response to regulatory changes and communicate these updates to all relevant stakeholders.
  • Reporting and Monitoring: Regular internal reporting ensures that compliance status is monitored, and necessary documentation is readily available for external audits and inspections.

Research Review Process

1. Research Initiation

  • Topic Selection and Approval
    • Compliance Screening: Before initiating any research project, the proposed topic undergoes a compliance screening to ensure it does not involve sensitive or non-public information.
    • Approval Workflow: we review and approves the research topic, ensuring alignment with regulatory standards and internal policies.
  • Access Control
    • Data Access Restrictions: Researchers are granted access only to information pertinent to their projects, minimizing the risk of inadvertent exposure to insider or non-public data.
    • Secure Information Systems: All data and research materials are stored in secure, encrypted systems with robust access controls.

2. Data Collection and Handling

  • Source Verification
    • Reliable Sources: Data is collected exclusively from reputable and publicly available sources, such as official financial statements, regulatory filings, and credible news outlets.
    • Source Documentation: Every data source is documented meticulously to ensure transparency and traceability.
  • Insider Information Prevention
    • No Insider Access: Researchers are prohibited from accessing or using insider information. Strict policies are in place to prevent the sharing of material non-public information within the firm.
    • Training and Awareness: Regular training sessions educate employees about the dangers and legal implications of insider trading and the importance of maintaining information integrity.

3. Research Analysis and Drafting

  • Compliance Integration
    • Regulatory Guidelines Adherence: Research methodologies and analysis techniques adhere strictly to guidelines set forth by regulatory bodies such as the SEC and FINRA.
  • Internal Reviews
    • Peer Review: Each research draft undergoes a peer review process where fellow analysts evaluate the content for accuracy, compliance, and objectivity

4. Legal Risk Mitigation

  • Legal Consultation
    • Pre-Publication Legal Review: All research reports are reviewed carefully to ensure they do not expose Convequity to legal liabilities.
    • Disclaimers and Disclosures: Proper disclaimers and disclosures are included in all reports to clarify the scope of the analysis and mitigate potential legal risks.
  • Risk Assessment
    • Continuous Risk Monitoring: Ongoing assessments identify and address emerging legal risks associated with research activities.
    • Incident Response Plan: A well-defined incident response plan is in place to handle any compliance breaches or legal challenges swiftly and effectively.

5. Report Finalization and Dissemination

  • Secure Distribution
    • Controlled Access: Reports are distributed through secure channels, ensuring that only authorized clients receive the information.
    • Record-Keeping: Detailed records of report distribution are maintained for audit purposes and to demonstrate compliance with regulatory requirements.

6. Post-Publication Monitoring

  • Ongoing Compliance Audits
    • Regular Audits: Periodic audits of published research ensure continued compliance and identify areas for improvement.
    • Feedback Mechanism: Clients and stakeholders can provide feedback on reports, which is reviewed to enhance future compliance and quality.
  • Continuous Improvement
    • Policy Updates: Compliance policies are regularly updated to reflect changes in regulations and industry best practices.

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