How to deal with potential conflict of interest?

Guidance for Issuer Paid research

有潜在的利益冲突，但是还是允许的

研究报告的费用，不能直接或间接和研究的结果挂钩

Must fully disclose potential conflict of interest,  including the nature of compensation.  If not=> misleading investors

Conduct a thorough analysis of the company’s financial statements based on public information,  benchmarking within a peer group and industry analysis.

Distinguish between fact and opinion.

Recommended procedures for Compliance

Protect the integrity of opinions – unbiased opinion and adequate system.

Create a restricted list for corporate client if not willing to issue adverse opinion and distribute only factual information about companies on the list. （如果不想发表负面意见，可以加入restricted list）

Restrict special cost arrangements – “pay it yourself”;  not reimbursed by corporate issuer;  limit use of corporate aircraft to situations in which commercial transportation is not available;  issuer shouldn’t always host the analyst. （不能总是由issuer请客）

Limit gifts：Customary and ordinary business related entertainment is okay as long as its purpose is not to influence independence;  based on local customs and whether the limit is per gift or annual total amount.（礼物不仅看单个价值，还要参考总价值）