Policy Statements ::

Protecting the Integrity of Public Markets
January 2011

Revere Data, LLC fully supports all efforts by regulatory agencies and market participants to maintain the integrity of our capital markets.
 
The Revere Hierarchy™ and RISC™ industry classification systems are designed to provide the most granular and up-to-date analysis on the competitive landscape of U.S. and international equity markets. In their effort to remain abreast of industry dynamics, Revere Data, LLC’s employees may engage in conversations with industry experts and apply insights learned into the maintenance of Revere Data, LLC’s industry classification hierarchy structure. Because of the reliance by Revere Data, LLC on industry experts and because of the potential that the information gleamed from these experts by Revere Data, LLC employees may include material non-public information that may be unintentionally or intentionally misused, Revere Data, LLC has adopted the following policies:
 
It is the policy of Revere Data, LLC that any industry experts engaged by Revere Data, LLC:
  • are not to be compensated either directly or indirectly by Revere Data, LLC or its employees, agents or representatives; 
  • are not to be privy to the proprietary details of Revere Data, LLC’s research methodology; and
  • are not to participate in Revere Data, LLC’s internal research process.
 
Further, it is the policy of Revere Data, LLC that non-public material information shall not be included and or reflected in Revere Data’s data feed and or data base services.
 
Further, it is the policy of Revere Data, LLC that employees are not to knowingly engage in activities that would cause them to become into possession of material non-public information.
 
Further, it is the policy of Revere Data, LLC that employees who come into possession of material non-public information that could affect the value of an investment during their employment are prohibited from acting or causing others to act on any such information and shall without delay report the possession of the material nonpublic information to the chief operating officer of Revere Data, LLC.
 
And, further, it is the policy of Revere Data, LLC that as a condition of continuing employment with Revere Data, LLC, each employee shall sign an acknowledgment that they have received this policy statement, that they understand the terms and reasons for this policy statement, and that they agree to conduct themselves in a manner consistent with this policy statement.
 
DISCLAIMER: This Revere Data, LLC policy statement does not create third-party rights or duties that would not already exist if this policy statement had not been made publicly available, and this policy statement does not form part of any contract between Revere Data, LLC and any client or prospective client.
 
For inquiries into Revere Data, LLC’s Statement on Protecting the Integrity of the Public Markets please contact:
 
Daniel McCafferty, Director, Research
(415) 782-0454 x205  dmccaffferty@reveredata.com
 
Stuart Bell, Managing Director, Global Client Solutions
(415) 782-0454 x365  sbell@reveredata.com