Compliance
About Convequity & Regulatory Status
Convequity Ltd is an independent equity research provider founded in July 2019. The firm is registered in the United Kingdom and operates fully remotely. All research is produced by the firm's senior analysts, who are directly involved in every stage of report production.
Convequity is not authorised or regulated by the Financial Conduct Authority, and is not registered with the U.S. Securities and Exchange Commission or any other securities regulator. Convequity does not carry on regulated activities: we do not provide personal recommendations, manage assets, hold client money, execute transactions, or solicit investments. Our research is impersonal, is distributed to all subscribers on identical terms, and does not take into account the individual circumstances of any recipient. In the United Kingdom, our publications are produced in reliance on the exclusion for periodical publications under Article 54 of the Financial Services and Markets Act 2000 (Regulated Activities Order) 2001. In the United States, we rely on the "publisher's exclusion" under Section 202(a)(11)(D) of the Investment Advisers Act of 1940, as interpreted in Lowe v. SEC, as a bona fide publication of general and regular circulation.
Nature of Our Research (Important Notice)
Our research is provided for informational purposes only. It does not constitute investment advice, a personal recommendation, an offer, or a solicitation to buy or sell any security. Nothing we publish takes into account your objectives, financial situation, or needs, and no client, advisory, or fiduciary relationship is created by your subscription or your reading of our research. You should conduct your own due diligence and, where appropriate, consult a regulated financial adviser before making any investment decision. Past performance is not indicative of future results, and forward-looking statements in our research reflect our opinions as of the publication date only, which we are under no obligation to update.
Conflicts of Interest & Position Disclosure
We operate on a principle of full, live, public transparency rather than confidential internal monitoring. Our research informs a technology-focused Smart Portfolio available on the eToro platform, operated in partnership with NewDeal Invest, a Danish authorised investment manager, and eToro. Discretionary portfolio management rests solely with NewDeal Invest as the authorised manager; eToro handles all investor onboarding, suitability, custody, and execution. Convequity provides research and analysis only, does not manage assets, does not hold client money, and does not solicit investment in the portfolio through this website.
All portfolio positions are publicly viewable at all times, both on eToro and on this website. Readers should assume that Convequity's principals, and the portfolio our research informs, may hold positions in any company we cover. This live disclosure is available to every reader before they act on our research. We receive no compensation of any kind from the companies we cover: no sponsored research, no investment banking, no advertising, no consulting relationships with covered issuers.
Personal Account Trading & Publication Blackout Policy
Convequity maintains a written personal account trading policy binding on all research staff. Its core provisions are: (1) no member of the firm, nor the portfolio via recommendations to NewDeal Invest, may initiate or change a position in a covered security from 5 trading days before through 2 trading days after publication of research on that security; (2) each analyst attests quarterly, subject to peer review, that all personal holdings are consistent with the policy and with our public disclosures; and (3) as all positions in the Smart Portfolio are publicly visible in real time, compliance with the blackout rule is externally verifiable by anyone, at any time.
Research Sourcing & Material Non-Public Information
All Convequity research is based exclusively on publicly available information: earnings calls, public CXO interviews, regulatory filings, company websites and blogs, product documentation and demos, videos, and public online communities. We may monitor public discussion on platforms such as Reddit and X for sentiment and idea generation, but all factual claims are verified against primary public sources before publication.
We do not use expert networks, do not conduct private conversations with company insiders, officials, or journalists in connection with our research, do not take corporate access or management meetings, do not hold press passes, and do not purchase non-public or paid third-party datasets. In the event that any member of the firm inadvertently receives information they believe may be material and non-public, our written policy requires that the information not be used or further disseminated, that the rest of the research team be notified immediately, and that coverage of and trading in the affected security be suspended until the information is public or stale. A senior analyst holding the CFA Charter reviews every report prior to publication specifically to verify that all information used is publicly available.
Research Review & Distribution
Every report is reviewed by a non-authoring senior analyst before publication, a review that covers analytical quality, factual accuracy, and sourcing compliance. All Premium subscribers receive published research simultaneously; no subscriber, institutional or retail, receives early access. Institutional clients may commission bespoke research and analyst calls on companies within our coverage area; bespoke work is subject to the same sourcing, MNPI, and blackout policies as published research.
Professional Standards
Convequity's research leadership includes a CFA Charterholder bound by the CFA Institute Code of Ethics and Standards of Professional Conduct, including its provisions on material non-public information, diligence, independence and objectivity, and fair dealing. All Convequity research adheres to these standards, and the CFA Institute's disciplinary process provides an external accountability mechanism.
Jurisdictional Notice
Our research is not directed at any person in any jurisdiction where its publication or availability would be contrary to local law or regulation, and persons subject to such restrictions must not access it. Our research is distributed globally as an impersonal publication and is not tailored to the laws of any specific jurisdiction.
Complaints, Errors & Contact
If you believe any of our published research contains a factual error, or you wish to raise a compliance-related concern, contact us at compliance@convequity.com. We review all such reports, and where we determine a material factual error was published, we issue a correction to all subscribers. Records of research publications, review sign-offs, and subscriber communications are retained for a minimum of five years.
Compliance FAQ
Is Convequity regulated by the FCA or registered with the SEC?
No. Convequity is an independent research provider and does not carry on regulated activities. See the Regulatory Status section above for the specific exclusions we rely on in the UK and US.
Does Convequity use expert networks, management access, channel checks involving private conversations, or paid third-party data?
No, none of these. All research is based exclusively on publicly available information, as detailed in the Research Sourcing section above.
Does Convequity speak with public company employees, government officials, or journalists in connection with its research?
No.
What happens if Convequity inadvertently receives material non-public information?
Our written MNPI policy requires quarantine of the information, immediate notification of the rest of the research team, and suspension of coverage of and trading in the affected security. See the Research Sourcing section above.
Do Convequity's personnel trade in the securities they cover?
The portfolio our research informs, and potentially members of the firm personally, may hold positions in covered companies. All portfolio positions are publicly disclosed in real time, and a written blackout policy prohibits position changes around publication. See the Conflicts of Interest and Personal Account Trading sections above.
Who manages the eToro Smart Portfolio?
Discretionary management rests with NewDeal Invest, a Danish authorised investment manager. Convequity provides research input only and does not manage assets or hold client money.
Does Convequity maintain a restricted list and personal account trading policy?
We maintain a written personal account trading policy - see the Personal Account Trading & Publication Blackout Policy section above. We do not maintain a restricted list: that control is designed for investment banks that house broker-dealer or corporate finance businesses alongside equity research under one roof. Convequity conducts research only, has no such relationships with covered companies, and receives no non-public information from them, so there is no information flow for a restricted list to gate. Our publication blackout rule governs trading around research instead.
Is research distributed to all subscribers simultaneously?
Yes. No subscriber receives early access. Bespoke institutional research is separate from, and does not preview, published research.
What is the pre-publication review process?
Every report is reviewed by a non-authoring senior analyst, and a CFA Charterholder verifies sourcing compliance on every report before publication.
Does Convequity receive compensation from companies it covers?
No. We accept no sponsored research, banking, advertising, or consulting fees from covered issuers. Our revenue comes solely from subscriptions and bespoke institutional research.
Does Convequity perform web scraping or use alternative data?
No. We may manually monitor public discussion on platforms such as Reddit and X, but we do not scrape data or purchase alternative datasets.
Does Convequity use AI tools in producing research?
Yes. We use frontier AI models from providers including OpenAI, Anthropic, xAI, Google, Meta, and Thinking Machines Lab, alongside associated tooling, to support drafting, analysis, and research workflows. All AI-assisted output is reviewed, verified, and approved by our senior analysts before publication, and accountability for every published conclusion rests with the human analysts. No subscriber data or non-public information is entered into third-party AI tools.
Does Convequity offer corporate access, and do employees hold press passes?
No to both.
Do subscribers have access to the publishing analysts?
Retail subscribers do not. Institutional clients may access the analysts via scheduled analyst calls.
What formal compliance training does Convequity conduct?
As a boutique firm of fewer than 10 people, we do not run a classroom-style program. All research staff complete an annual review and written attestation of our policies (MNPI, personal trading, sourcing, conflicts), and our research leadership's CFA Charterholder obligations include ongoing ethics standards.
How long are records retained?
Research publications, review records, and subscriber communications are retained for a minimum of five years.
Does Convequity carry professional indemnity insurance?
No. Given our impersonal publication model - we provide no personal recommendations, manage no assets, and hold no client money - combined with the liability disclaimers governing all our research, we have assessed that professional indemnity cover is not necessary for our business model. We keep this assessment under periodic review.