HAMPTON SECURITIES STATEMENT OF RESEARCH POLICIES AS MANDATED
BY IIROC RULE 3400
Separation of research and research reports from influence by the firm’s investment banking division.
Hampton Securities has no current investment banking involvements. If, in the future, we have such involvements, our policies and procedures will comply with IIROC Research Rule 3400.
Issuance of a research report where the firm or analyst has a business or advisory role with the company in the report, or where the firm or analyst anticipates business from the company and times, or slants, the report favorably, or where the firm has, is, or expects to perform underwriting services for the company.
Hampton Securities has no corporate advisory or underwriting involvements with securities held by our clients. Should such involvements occur with a security issuer whose securities are held by our clients, or recommended, IIROC policies, prohibitions and disclosures will be followed.
Disclosure of staff or analysts positions in research reported securities. Monitoring of analyst and staff holdings and trading of research covered securities, with possible prohibitions of certain such holding or trading.
Hampton Securities has procedures, controls and monitoring to ensure that client trades and client positions take precedence over any trading activity Hampton staff may engage in. These safeguards include:
- Scrutiny of thinly traded securities, where participation by a Hampton employee might have any meaningful effect on price, trading volume or stock performance.
- Generally recommending broadly traded and liquid securities, which allow ease of position building and liquidation.
- Monitoring of all staff trade orders prior to trade entry, to ensure full compliance with client preferential treatment. Daily monitoring of all trading activity, to ensure full client preferential treatment.
- Routine IIROC audits to ensure client preferential treatment.
- Portfolio monitoring to ensure that clients have preferential opportunity to participate in accumulation of securities we may favor and hold, and in the disposition of such securities.
General Disclosure Requirements
IIROC Research Rule 3400 requires full disclosure of firm involvements in investment banking, corporate advisory or business relationships, and staff activities or involvements with issuers of securities that are covered by a firm’s research. In addition to prohibited or proscribed involvements, Rule 3400 requires disclosure of a variety of other relationships might be deemed, by an investor who was informed of them, to be of material concern in assessing the objectivity of the firm’s research comment.
Hampton Securities will fully disclose any material relationship or involvement with any securities issuer of a security covered in our research.
Other General Requirements
Rule 3400 specifies professional methodologies and supervision for a firm’s research. Firms are required to explain ranking and evaluative methods used. Further disclosures deal with publicly stating research policies, and the requirement to make any research widely available. The firm must disclose if it is a market maker in a recommended security.
Research Dissemination Policies
Hampton posts its research reports on its website, giving clients, and the general public, access to the reports at the same time.
Disclosure of Ranking, Valuation Methods, Price Targets and General Methodologies
Hampton does not conduct general sector rankings, or general rankings of a wide universe of companies within a sector. Hampton selects individual sectors or companies that we believe offer attractive investment prospects to our clients.
Our views or evaluative targets are limited to a selected range of companies we feel are of interest at any particular time.
Our rating, or target prices, where made, are derived from generally accepted standards of financial analysis, from observation of comparative targets, viewpoints and expectations from other research analysts covering the company or sector, and from extensive experience and observation of the securities markets over many years.
Market Making Activities
Hampton will disclose if it is a market maker in any recommended security.
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