RenkoEdge makes available investment ideas regarding one or more markets, issuers, instruments or contracts, including but not limited to, securities, commodities, currencies or any financial instrument or derivative contracts.  

Our policy establishes arrangements, systems and procedures appropriate and proportionate to the scale, size and nature of the business that seek to prevent, detect and report abusive practices or suspicious trades or trade ideas. RenkoEdge follows the EU’s Market Abuse Regulation and the FCA’s Market Conduct sourcebook which set out the types of behaviour which can amount to market abuse when trading in financial instruments on EU trading venues.

Inside Information
RenkoEdge further follows FCA guidance in implementing these policies and procedures, which also satisfy SEC requirements designed to prevent the misuse of inside information as defined by such guidance. RenkoEdge forbids its staff from researching, making any investment recommendations or trading, either personally or on behalf of others, on the basis of Inside Information, in breach of the Market Abuse Regulation.

Training 
The training ensures that members of RenkoEdge idea generation team are aware of the requirements and prohibitions of the market abuse regime and the measures RenkoEdge has adopted. Training is arranged by the compliance department. RenkoEdge provides training to all new employees as part of their initial Compliance Undertaking and at least annually thereafter.

Identification of potentially suspicious actions 
RenkoEdge is a provider of investment ideas and does not enter the market to execute trades for itself nor on behalf of others.

Procedures and controls 
RenkoEdge service providers may not engage in any idea recommendation, research or advice the purchase or sale of an issuer’s securities whilst in possession of inside information about such issuer. Service providers coming into possession of potential inside information must not communicate this information to anyone, whether internal or external to RenkoEdge.

RenkoEdge service providers may be at a heightened risk of coming into contact with inside information when staff is:

• Attending analyst days or while conversing with investment analysts at other firms. RenkoEdge staff must avoid information that may include potential inside information known by such individuals or market sensitive information about forthcoming research publications
• Contact with companies represents a part of RenkoEdge’s investment idea generation activity. RenkoEdge may make investment decisions on the basis of conclusions formed through such contacts, together with analysis of publicly-available information regarding worldwide companies. In the course of these contacts, a member of staff should guard against becoming aware of information that may constitute inside information about a company.

Banned List 
Compliance maintains a Banned List of all securities where, through our conversation with companies and dealings with clients, brokers or any other party, RenkoEdge is deemed to have inside information in relation to the underlying company.