Compliance FAQ

Data Sourcing

Q. Does FlowPro use any non-publicly available or third-party sources?

A. Yes, in that we buy in data from third parties under licence (that is non-public; that they are selling privately for profit). No, in that we do not use any data that any member of the public could not also obtain themselves in a regular, lawful way from either publicly available (free) or commercially available sources.

Q. Is any web scraping used in connection with FlowPro?

A. Yes, in that we use technologies to speed up the process of collection of data from publicly available websites that would otherwise be collected more slowly by humans; where the data has been placed on those websites for free, with no firewall, and with the expectation that it will be used by anyone, most probably for making investment decisions. For example, data placed by a Central Bank or a Finance Ministry on their website relating to the structure of a government bond market.

Q. Does Exante Data speak with any individuals as part of its sourcing for the FlowPro product, for example public company employees, government officials, journalists)? If so, please detail any policies or procedures surrounding such conversations.

A. No

Data Processing

Q. Does Exante Data utilise any Generative AI and/or large language models (LLMs) to create the FlowPro product? 

A. No

Research Distribution

Q. Please describe the review process the FlowPro product undergoes prior to publication.

A. Michael Trounce, Director of FlowPro, is responsible for the product. Mike is the primary creator of research publications, and takes every effort to ensure they are accurate. Where publications have been authored by other members of Exante Data, Mike reviews them before publication.

Q. Is the product distributed to all subscribing firms simultaneously?

A. Yes. We use a commercial email distribution service to ensure deliverability is managed in this way.

Data Coverage

Q. Does FlowPro contain equity-specific information and/or investment recommendations?

A. No

Compliance Policies

Q. Please describe any compliance policies currently in place, such as annual trainings, written documentation, external legal counsel/compliance consultants, etc. Please provide copies of any documentation you feel comfortable sharing.

A. Exante Data’s counsel is in-house. Staff members who work on FlowPro are trained under Mike Trounce. Policies are explained verbally.

Everyone at the firm adheres to our our web scraping/crawl and automated data collection protocols.

Everyone at the firm sign the Compliance Handbook as an integral part of their engagement with Exante Data.

Team

Q. How many employees are specifically focused on the FlowPro solution?

A. FlowPro makes considerable use of technology, reducing the need to have a large and costly headcount. More than four, but fewer than ten employees help create FlowPro.

Clients

Q. Approximately how many entity subscribers does Exante currently have to the FlowPro product (a reasonable range is fine)? Of the total, how many of the subscribers are hedge funds/financial services firms?

A. A significant number of Exante Data’s clients subscribe to FlowPro as part of a bundle in which they obtain our flagship research and also FlowPro. That said, we have a small but growing number of standalone clients (not also subscribing to our Institutional Access service), of which we have more than three, but fewer than nine.

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