Ethics

1. We will never “front run” our research. When a company signs for coverage, the analyst will not trade (buy or sell) in that company’s shares until the relevant report has been published on this website and is available to the public. In the case of maintenance reports (e.g. results notes), the analyst will not trade in the respective company’s shares during the period from when the results are released on SENS on the JSE until we have published related results note on this website and it is available to the public.

2. We will disclose our collective holdings in the relevant company that we own at the time of publishing the report. Refer to the disclaimer at the end of each report for the disclosure of holdings at the date of publishing. Note that this disclosure reflects only a point in time, though, and subsequent relevant holdings may have changed.

3. While we have sold our “appearance” of independence by offering commissioned research, we will strive to act independently. Our contracts for coverage of a company include a clause specifically stating that we cannot and will not give the company any guarantee, warranty or similar assurance regarding our forecasts, valuations or any subjective opinion expressed in the research we published about them. Furthermore, Blue Gem Research and its internal pre-publishing process aims to ensure–while the research is of sufficient quality to be published–the Analyst’s own opinions expressed therein remain unaltered, changed or influenced in any way, other than to ensure that the Analyst can reasonably and logically justify them.