5. Access & Distribution Controls

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  1. Firms will track internal distribution of external research, especially if it involves bespoke, high value content created by the provider for the asset management firm. If the distribution of bespoke research goes beyond the access provided for by the specific research budget applicable then that research must be incorporated into the valuation model and budget unless discarded without consumption.
  2. For published research of a generic and lower value nature some sharing of content or ideas will be inevitable and impracticable to prohibit.
  3. Research cannot be distributed from internal sources across separate research budgets or across regional offices in order to circumvent charges. Research paid for in countries outside the EU in a bundled rate cannot be sent to individuals in Europe unless already included in the research budget.

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