Guidance
Do not let the investment process be influenced by any external sources. Modest gifts are permitted. Allocation of shares in oversubscribed IPOs to personal accounts is NOT permitted. Distinguish between gifts from clients and gifts from entities seeking influence to the detriment of the client. Gifts must be disclosed to the member’s employer in any case, either prior to acceptance if possible, or subsequently.
Guidance—Investment Banking Relationships
Do not be pressured by sell-side firms to issue favorable research on current or prospective investment-banking clients. It is appropriate to have analysts work with investment bankers in “road shows” only when the conflicts are adequately and elfectively managed and disclosed. Be sure there are effective “firewalls” between research/investment management and investment banking activities.
Guidance—Public Companies
Analysts should not be pressured to issue favorable research by the companies they follow. Do not confine research to discussions with company management, but rather use a variety of sources, including suppliers, customers, and competitors.
Guidance—Buy-Side Clients
Buy-side clients may try to pressure sell-side analysts. Portfolio managers may have large positions in a particular security, and a rating downgrade may have an effect on the portfolio performance. As a portfolio manager, there is a responsibility to respect and foster intellectual honesty of sell-side research.
Guidance—Fund Manager and Custodial Relationships
Members responsible for selecting outside managers should not accept gifts, entertainment, or travel that might be perceived as impairing their objectivity.
Guidance—Performance Measurement and Attribution
Performance analysts may experience pressure from investment managers who have produced poor results or acted outside their mandate. Members and candidates who analyze performance must not let such influences affect their analysis.
Guidance—Manager Selection
Members and candidates must exercise independence and objectivity when they select investment managers. They should not accept gifts or other compensation that could be seen as influencing their hiring decisions, nor should they offer compensation when seeking to be hired as investment managers. The responsibility to maintain independence and objectivity applies to all a member or candidate’s hiring and firing decisions, not just those that involve investment management.
Guidance—Credit Rating Agencies
Members employed by credit rating firms should make sure that procedures prevent undue influence by the firm issuing the securities. Members who use credit ratings should be aware of this potential conflict of interest and consider whether independent analysis is warranted.
Guidance—Issuer-Paid Research
Remember that this type of research is fraught with potential conflicts. Analysts’ compensation for preparing such research should be limited, and the preference is for a flat fee, without regard to conclusions or the report’s recommendations.
Guidance—Travel
Best practice is for analysts to pay for their own commercial travel when attending information events or tours sponsored by the firm being analyzed.