Research: Investor Protection

Caris & Company, Inc. has adopted the following principles to eliminate the potential conflicts of interest that may arise out of a relationship between the Investment Banking and Research Departments:

• Like all firm employees, analysts receive compensation that is impacted by overall firm profitability. In addition, the analyst's compensation is based on their stock recommendation performance and productivity. The quality of the analyst's research and overall ratings received by clients, sales force and peers independent of the firms' investment banking department. Analysts, however, are not compensated for investment banking services transactions.
• Investment banking has no input into analyst compensation;
• A review committee approves all research recommendations;
• Discontinuation of coverage is disclosed with an explanation;
• Research reports disclose whether the firm has received or is entitled to receive compensation from a covered company over the past 12 months; and
• The compliance department monitors the process to ensure compliance with the principles.