Conflicts of Interest

Our founder is an investor

Michael Harlan invests his own money, including in individual securities.

Ticker Mavericks is a research publication. It is not his portfolio, and the two are separate. But he may hold positions in securities we cover, and that is a conflict of interest. This page sets out what we do about it.

This statement is referenced in our Content and Platform Disclaimer and incorporated into our Subscriber Terms of Service.

1. Assume he owns what we cover

Mr. Harlan may hold a position in any security featured on the Platform.

We do not publish which securities he holds, in what direction, in what size, at what price, or on what date, and we do not undertake to publish any of that.

2. He does not trade around our publications

Mr. Harlan does not buy or sell any security from the moment it is shortlisted for research until seven (7) trading days after we have published on it. Where a shortlisted security is not published, the restriction ends when it leaves the shortlist.

For this purpose, publishedmeans the publication of an Asymmetric Flag on that security. Watchlist Intelligence briefs, Watchlist entries, and Curator’s Highlights changes report on or organise securities we have already flagged; they do not re-start this period.

Shortlisted means selected by the screening rules and passed to our research agents. It does not mean merely screened; our engine screens several thousand securities every day, and the shortlist is the small number that survive.

A trading day is a day on which the New York Stock Exchange is open for trading.

He cannot act ahead of our subscribers, and he cannot sell into a price movement our own work has caused.

Our research is produced automatically and published on a fixed daily schedule. He learns which securities the engine has surfaced at the same time subscribers do, and has no advance knowledge of what it will surface. Where he submits a security to the pipeline himself, he knows it is being screened before anyone else does — and from that moment the rule above applies to it, whether or not we ultimately publish on it.

2.1 Long only — he cannot bet against what we publish

He does not hold any short position, put option, written call, or other instrument that profits from a decline in the price of a security we cover, and he may not use any instrument to obtain economically what this section prohibits directly.

Ticker Mavericks publishes research on companies we believe the market has mispriced to the downside. He cannot profit from our being wrong.

2.2 What this rule does not restrict

This statement applies to individual securities we cover. It does not restrict his investing generally.

It does not apply to broad-based index funds, exchange-traded funds, mutual funds, or similar pooled vehicles that he does not direct and that were not selected for exposure to a particular security we cover. A pooled vehicle selected for its exposure to a particular security we cover is treated as a position in that security.

3. No company pays us

Neither the Company nor Mr. Harlan has ever accepted, or will accept, any compensation — cash, securities, free products or services, affiliate fees, or otherwise — from any company, investor-relations firm, promoter, or underwriter in exchange for covering, featuring, or mentioning any security.

No company can pay to appear on Ticker Mavericks, and none ever has.

4. What this statement does not do

It does not eliminate the conflict. It constrains it, and it tells you it exists. A conflict of interest that is disclosed and constrained is still a conflict of interest.

It does not mean his positions reflect our research, or the reverse. He may hold securities we have never covered. He may hold none of the securities we cover. His views may differ from what our research says, and our research may simply be wrong.

It does not make our research a recommendation. Nothing we publish is a recommendation to buy, sell, or hold any security, and nothing on this page changes that. See our Content and Platform Disclaimer.

5. This statement is voluntary

Ticker Mavericks is a publisher of financial research and educational content. We are not an investment adviser, broker-dealer, financial planner, or fiduciary, and we are not registered as such with the U.S. Securities and Exchange Commission, with any state securities regulator, or with FINRA.

No law, rule, or regulator requires us to restrict Mr. Harlan’s trading, or to publish this statement. We do it because we think you are entitled to know.

Adopting and publishing this statement does not create an advisory, fiduciary, agency, or client relationship between you and the Company, does not indicate that any such relationship exists, and does not indicate that we are subject to any regime that would require one. It does not make our content a recommendation, and it does not make us responsible for your investment decisions.

We may amend, narrow, or withdraw this statement. Any change will be posted here with a revised version number and effective date, takes effect prospectively only, and will not retroactively permit a transaction that was prohibited when it was made. The previous version will remain accessible. Where a change narrows a restriction or reduces what we disclose, we will identify it as such in the version history below rather than making the change silently.

While a version of this statement is in effect, it is accurate, we operate it, and we hold ourselves to it.

6. Version history