Personal Trading Policy

Why this page exists

Michael Harlan, the founder of Ticker Mavericks, may hold positions in securities that Ticker Mavericks covers.

That creates a conflict of interest. This page sets out, completely, what he is and is not permitted to do about it, and how you will know where he stands on any security we publish.

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

1. Who this policy covers

Michael Harlan, and any future employee, contractor, or affiliate of the Company who has access to Ticker Mavericks research before it is published.

2. What counts as a security we cover

A covered security is any security that has been, or is about to be, the subject of any Ticker Mavericks content — a flag, a research memo, a Watchlist entry, a Curator’s Highlights entry, a newsletter issue, or a social media post.

A security becomes covered the moment it enters our screening shortlist — before it is published, and before anyone outside the system knows it is a candidate.

A publication event is any moment a covered security appears in content we publish. A security can have many publication events over time, and each one re-starts the restrictions below.

Securities we do not cover are not subject to this policy. Mr. Harlan’s holdings in securities Ticker Mavericks has never covered create no conflict with our research, are not restricted by this policy, and are not published.

3. The rules

3.1 No trading before publication

Mr. Harlan may not buy, sell, increase, or reduce any position in a security from the moment it enters our screening shortlist until it has been published.

In practice, he could not do so even if the rule did not exist. Our research pipeline is fully automated and publishes on a fixed daily schedule. No human reviews a flag before it is published, and Mr. Harlan sees each day’s flags at the same time subscribers do. He has no advance access to the output of the system.

3.2 A waiting period before he can buy

Mr. Harlan may not establish or increase a position in a covered security until at least three (3) trading days after it has been published to subscribers.

Subscribers receive the research, and the first opportunity to act on it, before he does.

3.3 A minimum holding period

Any position he establishes in a covered security must be held for at least thirty (30) calendar days.

3.4 He cannot sell into our own publications

Mr. Harlan may not sell, reduce, or close any position in a covered security within thirty (30) calendar days after any publication mentioning that security — regardless of when he established the position.

This applies to positions he has held for years, and it applies again every time we publish on that security.

3.5 Exits are disclosed before they happen

Any sale of a covered security is disclosed on the Platform before or at the same time as the sale — never afterward. You will know he is selling no later than he does.

3.6 Long only — he cannot bet against what we publish

Mr. Harlan may hold long positions in common equity, and long options, in covered securities, subject to all the rules above.

He is prohibited from holding any short position, put option, written call, or any other instrument that profits from a decline in the price of a security we cover.

Ticker Mavericks publishes research on companies we believe the market has mispriced to the downside. He is not permitted to take a position that would profit from our being wrong, or from a decline in a company we have written favorably about.

3.7 No money from the companies we cover

Neither the Company nor Mr. Harlan has ever accepted, or will accept, any compensation — cash, securities, 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. How you will know where he stands

Every flag, research memo, Watchlist entry, and Curator’s Highlights entry displays a position disclosure. It states whether Mr. Harlan holds a position in that security and, if he does, its direction, the date it was established, and the earliest date he is permitted to exit it.

Where he holds no position, the disclosure says so. The disclosure appears on every covered security, every time — not only when there is something to declare.

These disclosures are generated automatically from position data synchronized directly from his brokerage account. They are not typed in by hand, and they do not depend on anyone remembering to add them. If current position data is unavailable, publication is blocked rather than published without a disclosure.

A list of all current positions in covered securities is published at tickermavericks.com/positions.

5. What this policy does not do

It does not eliminate the conflict. It constrains it, and it makes it visible. 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 not hold 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.

6. Records and enforcement

Every trade in a covered security is logged with its date, direction, size, and price, and is supported by brokerage records. These records are retained for six (6) years.

If this policy is ever breached, we will disclose the breach on this page, together with what happened and what we did about it.

7. Changes to this policy

We may amend this policy. Any amendment will be posted here, with a revised version number and effective date, and the previous version will remain accessible.

We will not amend this policy retroactively to permit a transaction that was prohibited when it was made.