EXPERT COMPLIANCE SNAPSHOT PAGE 1 OF 2

Capvision strictly complies with the regulatory standards established by international regulative institutions, including but not limited to, laws
regarding insider trading, anti-bribery, and anti-corruption. You understand and acknowledge that by joining our network, and as an express condition
of initiating or continuing your participation in any Capvision activities, you have an obligation to abide by the laws of the jurisdictions in which
Capvision does business.

(1) Insider Trading & Information Sharing Restrictions (2) Expert Confidentiality Obligations

You must not disclose or attempt to use or personally benefit from any confidential
Insider trading is an unethical and illegal activity prohibited in jurisdictions all over the
information that is disclosed to or known by you because of your participation in Capvision
world as it creates an uneven advantage in markets that rely on a baseline of equity and
activities.
fairness.
 You may not disclose Capvision’s Client or project information to any third party under any
You are explicitly prohibited from engaging in the following behaviors:
circumstances (e.g. do not list Clients on your resume or online).
 Providing MNPI at any point during any activity involving or related to Capvision or its Clients.
 Prior to each project, you will be made aware of the nature of the business of each Capvision
SEE (PAGE 2) “WHAT IS MNPI?”
Client with whom you will collaborate; however, many Clients request to remain anonymous
throughout the consultation. Do not attempt to uncover the Client's identity.
 Soliciting, selling or trading any securities based on any information you have learned directly or
indirectly from Capvision Clients.
 Any Client identity, information about any actual or potential business, investment, trading
decisions or transactions of any Clients, are strictly confidential.
 Disclosing any information that you are obligated to keep confidential.
 You are not permitted to independently contact a Client before, during, or after a Capvision
You must decline to answer questions that would violate any ethical, legal, regulatory, or
project or activity without Capvision’s prior written authorization.
contractual obligations or constraints you are subject to.

(3) Anti-Bribery & Anti-Corruption (4) Expert Rights & Responsibilities

You are explicitly prohibited from engaging in the following behaviors:

 Paying, offering to pay, or authorizing any direct or indirect payment or anything of value to
It is your sole responsibility to confirm that your participation in any Capvision activity
anyone in an effort to influence that person to assist you, Capvision, or any Client of Capvision in
does not violate any confidentiality agreement or other obligation to which you are
obtaining information or securing any other business advantage.
subject.
 Accepting or implying that you accept – for yourself or on behalf of another person – from
 You are participating in Capvision activities in your individual capacity and not as a representative
Capvision’s Clients any direct or indirect payment or anything of value beyond the professional
or on behalf of any other company or organization, such as past or present employers.
fee agreed upon with Capvision as part of the formal engagement.
 If a Client contacts you without Capvision having arranged the interaction (including follow-up
 Agreeing or implying that you agree to allow the engagement at hand or any fees earned as a
enquiries, you must immediately notify uscompliance@capvision.com.
part of the engagement to facilitate you making a decision for or against any party.

1 If you have any questions, contact uscompliance@capvision.com.

 WHAT IS MNPI? PAGE 2 OF 2

MATERIAL NON-PUBLIC INFORMATION

Relevant to the market price of a security Not revealed to everyone in the Is it MNPI?
(e.g. stock in a public company) marketplace

 If you were an investor and knew this information
would you buy/sell or not buy/sell this stock
based on the information?
 Does this alter my perception of the company and
its place in the market?
 Has the information not yet been communicated
to the investment community via channels
available to the general public (e.g. press releases,
published articles, etc.)?
If you answered YES to these questions, the
information is MNPI and cannot be shared.
If a Client is requesting information which
could likely reveal MNPI, please notify
uscompliance@capvision.com.

IF YOU ARE CURRENTLY OR HAVE PREVIOUSLY WORKED FOR AN ISSUER OF SECURITIES, PAY CAREFUL ATTENTION, OR IF YOU WORK FOR AN
ENTITY THAT HAS ANNOUNCED AN INITIAL PUBLIC OFFERING (“IPO”), PAY CAREFUL ATTENTION!

You MUST decline to answer questions that would potentially disclose MNPI.
In the event that you end a consultation early due to innappropiate client questioning, you will still be compensated for your time commitment.
You must report innappropriate client questioning to Capvision’s Compliance Department (uscompliance@capvision.com).

See Below for Examples of Material Information (Non-Exhaustive List)

Revenue and earnings information; projections and forward-looking information; mergers, acquisitions, tender offers, joint ventures, or changes in assets (even if
preliminary); new products; developments about customers or suppliers, such as the loss of a major contract; changes in control or management; events regarding the
issuer’s securities, including defaults on strict securities; calls of securities for redemption; repurchase plans; stock splits; changes in dividends; changes to rights of securities
holders; public or private sales of securities; change in auditors or audit report; and bankruptcies or receiverships.

2 If you have any questions, contact uscompliance@capvision.com.