SAHLER RESEARCH PRINCIPALS AND COMPLIANCE 

Sahler Research is established on the core principals of integrity and professional excellence. Our clients’ interests are our top priority. We pride ourselves on our truly independent, proprietary research approach, and our ethical standards.

We specialize in grass roots, primary research; specifically, we collect large amounts of immaterial, publically available information to form a mosaic on overall industry trends. We stress the importance of compliance, and believe that broad-based, low- level surveys not only comply with Regulation FD, but also provide relevant insights into real-time business trends.

Our Research Approach:

  1. We avoid inducement: We generally do not provide payment or an incentive to an employee to encourage them to provide information they should not be providing; in the rare cases we do, this is disclosed. We also avoid utilizing expert networks to pay employees for survey work.

  2. We adhere to an employee’s duty of confidentiality: If interviewing an employee about their own company, we only interview public-facing employees, such as an owner or store manager, ensuring that they are aware of any specific confidentiality agreement they might have in place with their employer.

  3. We generally avoid interviewing employees of publicly traded companies: When we do occasionally speak with employees of a publically-traded company about their own overall trends, our questions are only qualitative in nature, and we avoid quantitative data such as actual sales, earnings, or profits (even if this data is only at the store level). In these cases, the client should notify the publicly traded company (IR, CFO, or CEO) to determine if there are any issues with the questions we plan to ask lower level employees.

  4. We prefer to interview operators that interact with the company that is the subject of our study: Specifically, we interview competitors, suppliers, sellers, third-party retailers, distributors, franchisees, or dealers. We believe it is prudent to avoid surveying an employee at a publicly traded company about his or her own overall store trends.

  5. We regularly screen our data for any material non-public information: We filter the data collected during our surveys to ensure that no individual pieces of information that has been collected could be construed to be either confidential or material non-public.

  6. We do not seek any information under false pretenses: We disclose to the interviewee that we are acting on behalf of a client and we accurately describe who we are and why we want the information.

Our Staff:

  1. We hire all of our staff on an independent contractual basis.

  2. We require new contractors to complete a rigorous interview and training process, particularly as it relates to Sahler Research’s compliance policies.

  3. We audit and monitor our staff member work on a daily basis to ensure the accuracy of our data, and that they are maintaining a professional conduct.

  4. Each independent contractor is required to sign Sahler Research’s Terms and Conditions annually, and upon hire. The Terms and Conditions contract requires contractors to, among other things:

    1. not seek any information under false pretenses;

    2. not solicit information that will violate a duty of confidentiality;

    3. not seek any confidential information, including material non-public information.

  5. Each independent contractor is required to review and complete annual training as it relates to Sahler Research’s compliance policies (our tutorials are available on request). These policies address issues such as:

    1. insider trading,

    2. dissemination of material non-public information,

    3. potential conflicts of interest,

    4. the treatment of sources,

    5. record maintenance,

    6. how we license research to our clients.

Our Clients:

  1. We allow clients to specify how we collect our data in accordance with our compliance policy.

  2. We do not offer investment opinions to clients, or publish investment recommendations.

  3. Our research is owned by the client who commissions the work: Our clients are permitted to use our data, with proper citation of Sahler Research, for any purpose and which may include reproduction, disclosure, transmission, publication, broadcast, and postings. We do not syndicate exclusive client research to other parties.

  4. We maintain client confidentiality.

  5. We do not manage money or trade securities, or make markets in securities. 

©2020 by Sahler Research