Code of conduct.
Our standard of integrity for employees, contractors, and partners — covering data integrity, market conduct, anti-bribery, confidentiality, and how to report concerns. Read alongside our Insider Trading Policy and Data Acquisition Policy.
1. Introduction
At FinancialReports, trust is our currency. Our clients—including hedge funds, asset managers, and academic institutions—rely on the integrity and accuracy of our data. This Code of Business Conduct outlines the ethical standards we expect from our employees, contractors, and partners. It should be read in conjunction with our specialized Insider Trading Policy and Data Acquisition Policy.
2. Data Integrity & Market Conduct
- Prohibition on Trading: Employees with access to our backend ingestion pipeline are prohibited from trading securities of companies where they have viewed material non-public filings before those filings are accessible to our general user base.
- Data Neutrality (FIFO): We do not alter, delay, or selectively release data to favor specific clients. Our processing pipeline operates on a strict First-In, First-Out (FIFO) basis to ensure equal market access for all subscribers.
3. Respect in the Workplace
We are committed to a work environment free from harassment, discrimination, and retaliation. We recruit, hire, and promote based on qualifications and merit, without regard to race, color, religion, gender, sexual orientation, or national origin.
4. Anti-Bribery, Corruption & Gifts
We comply with all applicable anti-bribery and corruption laws, including the UK Bribery Act and the US Foreign Corrupt Practices Act (FCPA).
- Bribery: We do not offer, give, or receive bribes or improper payments to obtain or retain business.
- Gifts & Hospitality: Employees may not accept gifts, entertainment, or favors from vendors or clients that could be perceived as influencing business decisions. Any gift with a value exceeding $100 (USD) must be disclosed to Compliance and, in most cases, returned or donated.
5. Confidentiality & Data Privacy
Protecting client data is paramount. We adhere to strict confidentiality protocols:
- Client Anonymity: We do not disclose the identity of our clients or their specific search queries to third parties, except where required by law.
- Search Privacy: We understand that a search query (e.g., searching for a specific small-cap company) can be a signal of investment intent. We treat search logs with the highest level of security classification.
6. Reporting Concerns
If you believe a violation of this Code has occurred, please report it immediately. We maintain a non-retaliation policy for reports made in good faith.