Code of Ethics

Overview

Vetta Research maintains a comprehensive Code of Ethics that governs the conduct of all personnel involved in the production and distribution of our investment research publications. This Code establishes standards of editorial integrity, transparency, and ethical behavior to protect our subscribers and maintain the credibility of our research.

Editorial Independence

All investment research published by Vetta Research is generated through proprietary algorithmic models and reviewed by our editorial team. We are committed to:

• Publishing research based solely on algorithmic output and rigorous analysis, free from external influence
• Never accepting compensation from third parties to feature, promote, or suppress any security in our publications
• Disclosing all material conflicts of interest, including personal holdings in covered securities
• Treating all subscribers equally — the same research is delivered to every subscriber simultaneously

Personal Trading Policy

Vetta Research personnel may hold positions in securities discussed in our publications. However, all personal trading is subject to strict internal policies designed to prevent front-running and other conflicts. Personnel are prohibited from trading on publication content before it is delivered to subscribers and must hold any position for a minimum period after a research recommendation is published.

Transparency Standards

We are committed to full transparency in our research process. This includes clearly disclosing the hypothetical nature of model portfolio performance, the methodology behind our algorithmic models, and any limitations of our approach. We present all years of our track record — including the bad ones — without cherry-picking or selective reporting.

Subscriber Protection

Vetta Research takes the following measures to protect subscribers:

• Clear and prominent disclaimers that our publications are research, not personalized investment advice
• Accurate representation of model portfolio performance with appropriate risk disclosures
• Secure handling of subscriber data and payment information via Stripe
• Easy cancellation process with no hidden fees or lock-in periods

Reporting Violations

Any subscriber or member of the public who believes that Vetta Research has violated this Code of Ethics may report the concern by contacting us at [email protected]. All reports will be reviewed promptly and taken seriously.