Investment Protection Principles
On February 1, 2003, Melvin & Company ("Melvin") adopted the Investment Protection Principles set forth by the State Treasurer of California, the State Treasurer of North Carolina, and the Comptroller of New York State.
Our principles are as follows:
- Sever the link between compensation for analysts and investment banking.
- Prohibit investment banking input into analysts' compensation.
- The President and Chief Compliance Officer review and approve all research recommendations.
- Upon discontinuation of research coverage of a company, we will disclose the coverage termination and the rationale for such termination.
- We will disclose, in research reports, whether the firm has received or is entitled to receive any compensation from a coverage company over the past 12 months.
- Melvin has established a monitoring process to ensure compliance with the principles.