Code of ethics

Preamble

hiboo is an online press service specialising in financial information and analysis. Its publications — articles, analysis notes, newsletters, videos and messages distributed on social media — are addressed to all of its readers and subscribers and constitute, for some of them, investment recommendations within the meaning of the European Market Abuse Regulation (Regulation (EU) No 596/2014, “MAR”).

On both counts, hiboo staff — executives, journalists, analyst-editors and regular contributors, hereinafter “the staff” — must comply with two complementary bodies of rules: press ethics on the one hand, and the rules applicable to producing and disseminating investment recommendations on the other.

This code is intended to guide staff in the situations in which they perform, or may be called upon to perform, their duties. It applies to every form of hiboo publication, regardless of the medium.

1. General principles

hiboo staff must comply with applicable law. They must:

Respect the integrity of financial markets and the rules that govern them.
Put the interest of readers and subscribers first, with objectivity, loyalty and fairness.
Carry out their editorial work according to an ethic that does them and the financial press honour, and encourage others to do the same.

Each staff member keeps their knowledge of the laws and regulations applicable to their work up to date and ensures they are complied with at all times.

2. Editorial ethics

hiboo staff observe the core principles of journalism:

Separation of genres. In every publication, clearly distinguish established, sourced facts from estimates, hypotheses or the newsroom’s opinion.

Correction. Publicly and without delay correct any published information that proves inaccurate.

Editorial independence. Accept no instruction, direct or indirect, from an issuer, advertiser, financial intermediary or any third party as to the content, tone or conclusions of publications. No hiboo publication may be paid for by an issuer or constitute disguised advertising.

No personalised advice. hiboo is a press organisation: its publications are addressed indiscriminately to all readers and never constitute personalised investment advice. Staff must not give a reader, subscriber or third party an individual recommendation based on that person’s circumstances.

Collective responsibility. hiboo publications result from collegial work published under the responsibility of the publisher. Each staff member keeps in mind that their statements, including in external contacts and on social media, engage hiboo’s responsibility and reputation, directly or indirectly.

3. Quality of analyses

Staff ensure their analyses are clear by stating the characteristics and risks of the investments under review. They refrain from reckless recommendations and set out, with supporting arguments, the assumptions underlying their analysis.

Return assumptions must come from the newsroom’s own reasoning, not solely from issuers’ statements. In any event, staff must be able to justify the reliability of their sources and of the reasoning used at the time their conclusions were produced.

4. Inside information

Within the meaning of Article 7 of MAR, inside information is information of a precise nature that has not been made public, relating, directly or indirectly, to one or more issuers or to one or more financial instruments, which, if it were made public, would be likely to have a significant effect on the prices of those instruments or of related financial instruments.

Unlawful use or disclosure of inside information is liable to administrative sanctions (AMF) and/or criminal sanctions.

When dealing with an issuer, staff make sure their counterpart knows they are speaking to a press organisation and that the exchange is intended to inform publications. It is for staff to ask the source whether information is confidential and likely to affect an issuer’s share price; disclosing inside information to the public is the issuer’s responsibility.

If in doubt as to whether information is inside information, staff refer it to hiboo management before any use.

If a staff member becomes aware of inside information, they must not:

carry out or cause to be carried out any market transaction, directly or through an intermediary, before the public has been informed;
disclose it to anyone, including colleagues, other than hiboo management;
use it in their editorial work, whether to prepare an analysis, an investment recommendation or any other content, in any form or by any means of communication.

Provided a publication contains no inside information and its author used none in forming their opinion, that publication should not in principle be treated as inside information, even if its dissemination would affect the share price of the company concerned.

5. Primacy of readers’ interests and equal treatment

hiboo publications have as their primary objective the interest of their recipients. Analyses reflect the newsroom’s independent judgement and objectivity, and are not distorted by the interests of hiboo, its executives or third parties.

No staff member may selectively give a reader, subscriber or third party, whatever the medium, research, recommendations or material changes of opinion on listed securities before they are disseminated simultaneously to all subscribers in the same category.

6. Gifts and benefits

Staff accept no gift, benefit or invitation, in any form, from readers, issuers, intermediaries or other third parties that could impair their independence of judgement or create a perception that it is impaired. Courtesy of symbolic value is allowed provided it creates no obligation, even a moral one.

7. Conflicts of interest and transparency

A staff member may occasionally face a conflict of interest: they then put readers’ interests first. They must not favour their personal interests, or those of hiboo, to the detriment of readers and users.

In accordance with Commission Delegated Regulation (EU) 2016/958 on the objective presentation of investment recommendations and the disclosure of conflicts of interest, each financial analysis published by hiboo states:

holdings in the issuer’s shares by the author, hiboo and/or its staff at the time the analysis is written and published;
holdings in the issuer’s shares by the author, hiboo and/or its staff seven days after the analysis is published.

To that end, staff inform management of their positions in securities followed by hiboo.

Any staff member who may hold a significant interest in an investment firm, or a business relationship with such a firm, avoids any interference by that firm in their work and must not communicate any information, analysis or recommendation to it before simultaneous dissemination to all subscribers in the same category.

8. Gathering information and relations with issuers

Staff gather information by analysing companies’ releases and corporate documents, following their technical, industrial, competitive, commercial and financial environment, attending meetings open to a large number of participants and general meetings, and through regular or occasional contact with companies.

The purpose of private interviews with companies under review is to place those companies and their development in context and to obtain clarification of information already made public. Staff do not use, in their work, confidential or inside information they may hold on issuers.

9. Personal dealings

No staff member may transact, directly or through an intermediary, in the shares:

of a newly covered company from the start of hiboo’s study and for a minimum of 7 days after the first publication of its financial analysis;
of a company featured in a hiboo video from the start of production and for a minimum of 7 days after publication;
of a company from its addition to (or removal from) hiboo’s “top picks” list and for a minimum of 7 days after that change;
of a company on a first entry into a portfolio followed by hiboo or a full exit (buy or sell), and for a minimum of 7 days after the move;
of a company whose analysis is updated, and for a minimum of 7 days after publication.

The list of companies in which all transactions are prohibited is published on hiboo’s intranet, in the “Dashboard” folder.

Staff, including members of management, undertake to provide, on any request from a member of management and within the following week, their securities-account and portfolio statements, unless they are under a discretionary mandate.

In general, direct investment in individual securities by a staff member is accepted by hiboo because it serves the company’s mission: the experience of being a shareholder feeds the quality of the information given to readers.

10. Sanction

Any breach of this code of ethics may be treated as serious misconduct.