COMPLIANCE

Compliance is at the very core of our culture and business practices. While our Fact Finders (“consultants”) provide valuable expertise to our select clients, there are necessary constraints.

Since our establishment in 2001, Mosaic has invested considerable man hours and financial resources to create our extensive compliance framework. Maintaining confidentiality is critical, particularly as it relates to material non-public information. Mosaic’s robust systems and checks and balances ensure that such information is not disseminated, keeping client interests and information confidential. Requisite conditions for our consultants include agreeing to and signing the Fact Finder Terms and Conditions of Participation contract, receiving necessary consents or waivers from appropriate parties, reviewing the Mosaic Compliance Procedures Manual & Code of Ethics and participation in our annual training program. Employees of public companies are not permitted to become Fact Finders.

All compliance documents and consultant biographies are available upon request. If you have any questions about our compliance framework, please email us by clicking here.

FACT FINDER REQUIREMENTS

Contract

To be eligible to participate in the Fact Finder Program consultants must sign and annually re-sign our Fact Finder Terms and Conditions.

Compliance Training

Consultants are required to complete training before they are permitted to participate in the Fact Finder Program and must also agree to participate in the annual training program.

Eligibility

Consultants must certify that he or she is not required to obtain any consents or waivers in order to participate in the Mosaic Fact Finder Program.

TRADING RESTRICTIONS

All of our employees are required to sign confidentiality agreements and are restricted from personal trading in securities on Mosaic’s research coverage list.

CLIENTS

For clients that want to be able to monitor the activities of portfolio managers and analysts, clients can produce proprietary questions for the consultant. These questions are vetted by Mosaic’s Chief Compliance Officer and the consultant prior to any contact between the client and consultant. Once the questions are approved, clients may request to have a call with the appropriate consultant. Consultants cannot directly contact a client unless Mosaic instructs them to do so. Clients are approved to speak with the consultants who have met the conditions in the Mosaic Research Compliance Overview.

COMPLIANCE DOCUMENTS

Compliance Overview

Fact Finder Terms and Conditions of Participation

Compliance Procedures Manual and Code of Ethics

Compliance Training

If you have any questions or would like to receive any of our compliance documents, please email us by clicking here.