In Practise Compliance Policy and Process

PURPOSE OF THIS POLICY

1. prohibit unlawful use of material non-public information (MNPI) by In Practise; and
2. prevent the disclosure to In Practise of MNPI, by contributors of content distributed by In Practise (Contributors), when creating that content.
3. prevent the disclosure to In Practise of MNPI, by contributors of content distributed by In Practise (Contributors), when creating that content.

WHAT IS MNPI

1. MNPI, also known as inside information, includes any company information or information relating to investments, whether directly or indirectly, which is not generally available and which, if generally available, would be likely to have an impact on the price of those investments or any related investments.
2. MNPI may be of a positive or negative nature, and can include:
   1. financial forecasts
   2. financial results
   3. strategic information, for example regarding acquisitions or disposals of other companies or assets
   4. product information; and
   5. developments in R&D

PROHIBITED USE

1. In Practise personnel shall not disclose or use any MNPI they receive for any purposes whatsoever. All MNPI shall be treated absolutely confidentially.
2. Specifically, In Practise personnel shall not trade on the basis of MNPI nor disclose MNPI to third parties to enable that third party to trade on the basis of MNPI.
3. All In Practise personnel shall treat MNPI in accordance with all applicable law and regulation. Breaches of applicable law and regulation may result in civil or criminal sanction or penalty.
4. Any MNPI shall remain subject of this restriction until one trading day after its publication or announcement to the general public by an authorised source or other lawful disclosure.
5. All In Practise personnel are responsible for reporting breaches of this policy to the founders of In Practise.

MNPI & CONTRIBUTOR CONTENT

1. In Practise shall notify all Contributors of this policy and remind Contributors that their content must not include any MNPI whatsoever.
2. In Practise shall not procure content from Contributors unless under the terms of a written agreement prohibiting the disclosure of MNPI, or warranting that Contributor content shall not contain MNPI.
3. All Contributors agree to an attestation stating they will not release any MNPI during the interview.
4. All Contributor content shall be reviewed by suitably qualified In Practise personnel, having undertaken appropriate training and having regard for this policy.
5. In Practise has reserved the right to edit Contributor content for the purposes of removing actual or potential MNPI.
6. Prior to distribution by In Practise, actual or potential MNPI appearing in Contributor content shall be removed from Contributor content.
7. In Practise does not distribute live Contributor content.
8. In Practise does not distribute Contributor content other than in its capacity as an independent publisher.

RECORD KEEPING

1. In Practise shall maintain a register of any actual or potential MNPI it receives, including any actual or potential MNPI removed from Contributor content. Such register shall be disclosed to law enforcement or regulators on their legitimate request.
2. Such register shall record, in respect of each receipt of actual or potential MNPI:
   1. in general terms only, the nature of such MNPI
   2. the In Practise personnel to receive such MNPI
   3. the circumstances in which such MNPI was received
   4. the date on which such MNPI was received; and
   5. the source of such MNPI.

TRAINING AND REVIEW

1. All In Practise personnel shall receive regular training on the proper treatment of MNPI and this policy.
2. This policy shall be subject to periodic review, with advice and guidance from external consultants as may be appropriate.

CONFIDENTIALITY

1. “Confidential Information” means any information or intellectual property rights that are clearly labelled or identified as confidential or ought reasonably to be treated as being confidential. Confidential Information includes MNPI, but excludes any information which is or becomes publicly known other than through a breach of this policy or other obligation of confidentiality.
2. You shall hold Confidential Information in confidence and not make Confidential Information available to any third party unless you have been authorised in writing by In Practise.
3. You shall take all steps necessary to ensure that Confidential Information is not disclosed or distributed in breach of this Policy.

COMPLIANCE PROCESS

1. Founding team

   1. The founders of In Practise were part of the founding team of a leading content business in the expert network industry. Over the last 7 years, the founders have each undertaken over 1,000 one-hour interviews with senior executives, building up deep experience in meeting the needs of institutional investors.
   2. The founders have experience with industry-standard compliance in asset management, having implemented compliance frameworks for teams producing over 4,000 interviews a year, ensuring no confidential or material non-public information is published.

2. Executive Vetting Process

   1. Each executive runs through a 30-minute pre-qualification vetting call where In Practise learns more about the executive's background and checks for NDA's.

3. Content

   1. In Practise produces internally-hosted and client-hosted interviews with executives of both private and public companies. Each published interview is pre-recorded 1-2 weeks before being released to users of In Practise.
   2. In Practise currently has thousands of users that access the material that is publicly available to any individual to sign up and subscribe for $400 annually.

4. Interview process

   1. Each interview is recorded, transcribed, and reviewed by In Practise internally by two separate individuals to ensure nothing released constitutes any form of material non-public information or confidential information.
   2. Each executive who consults through In Practise agrees to an attestation read by the client stating they will not release MNPI. Clients may also read their own custom attestations before speaking to any executive.
   3. Any content that is potentially MNPI or libellous is removed from the transcript.

5. Executive Terms of Engagement

   1. Each executive who contributes to In Practise signs terms of engagement which can be viewed here. By signing the In Practise terms, experts working with In Practise warrant that they will not disclose any MNPI, provide any investment advice, guidance, or infringe on any copyright.

6. Publishing independence

   1. In Practise is an independent publisher and has no tie with any corporation or institution.

QUESTIONS