Additional Disclosures

Trinity Delta is an equity research house focused on the healthcare, life sciences and related industries. The business is owned by the staff and operates on the basis of a genuine partnership. The team consists of highly qualified industry specialists, who have developed their knowledge and skills working at highly regarded institutions and investment houses. We pride ourselves on working to the highest possible standards, with this professionalism underpinning everything that we do at Trinity Delta.

Trinity Delta provides independent research services and the company covered in the research notes pays us a set fee in order for this research to be made available (technically known as the “issuer pays” model). The conclusions and opinions expressed in the reports reflect the professional views of the analysts named on the front page of every report. Whilst every reasonable effort is made to ensure that the information in the research is correct, this cannot be guaranteed. The report is intended to be clear, fair, and not misleading.

Trinity Delta has a personal dealing policy which debars staff and consultants from dealing in shares, bonds or other related instruments of companies which pay us for any services, including research. They may be allowed to hold such securities if they were owned prior to joining Trinity Delta or if they were held before the company appointed Trinity Delta. In such cases sales will only be allowed in limited circumstances, generally in the two weeks following publication of figures.

Trinity Delta does not buy or sell shares, either for its own account or for other parties and neither does it undertake investment business. We may provide investment banking services to corporate clients.

Trinity Delta does not make recommendations. Accordingly, we do not publish records of our past recommendations. Where a fair value price is given in a research note this is the theoretical result of a study of a range of possible outcomes, and not a forecast of a likely share price.

Trinity Delta may publish further notes on these companies but has no scheduled commitment and may cease to follow these companies without notice.

Trinity Delta provides research for the use of the professional investment community, market counterparties and sophisticated and high net worth investors as defined in the rules of the regulatory bodies. It is not intended to be made available to unsophisticated or retail investors. Anyone who is unsure of their categorisation should consult their professional advisors.

Our research is neither an offer, nor a solicitation, to buy or sell any security. Past performance of a security is not necessarily a guide to the future and the price of shares and bonds, and the income derived from them, may fall as well as rise and the amount realised may be less than the original sum invested.

In some cases research is only issued electronically, whilst in other cases printed research will be received by those on our distribution lists later than those subscribing to research electronically. This report may not be reproduced in whole or in part without prior permission from Trinity Delta.


Trinity Delta Code of Conduct

As context, Trinity Delta is a specialist equity research house focused on the healthcare, life sciences and related industries. We are experienced healthcare and life sciences analysts providing the highest quality service to companies in these sectors and to investors. We have expertise in the fields of the biotech, medtech, specialty pharma and consumer health sectors. We pride ourselves for our integrity and professionalism, where our word is our bond. This applies to our research, and all interactions with companies, the buyside and other partners. We also firmly believe that by putting our clients before ourselves, we create long term value for all our stakeholders.

Trinity Delta is an open and transparent organisation and partners should be aware that high standards of conduct and personal integrity are expected. This Code of Conduct applies to all partners and compliance with its terms is part of the contract between each partner and Trinity Delta. Essentially it sets our minimum standards for behaviour and seeks to adhere, with amendment as appropriate for a commercial organisation, with the seven principles of public life. Partners must ensure that they are familiar with the Code and that their actions comply with its provisions.

General principles

Partners are expected to act at all times in a professional manner. They should refrain from any illegal, dishonest or unethical conduct at all times, not just when they are providing services or representing Trinity Delta.

Acting in good faith, with honesty, integrity and probity Partners must take personal responsibility for adhering with this Code of Conduct. Partners must not act in a manner that may bring Trinity Delta into disrepute nor should they use their position for personal gain or to promote other interests.

Treating others with dignity and fairness Partners must treat all stakeholders with respect, dignity and fairness. They will comply with anti-discrimination requirements concerning matters of race, gender, age, disability, national origin, religion, sexual orientation, social and economic position, and marital status. Partners must respect all co-workers and the roles they perform, ensuring they are treated politely and fairly, with courtesy and dignity at all times.

Conflicts of interest Partners must disclose any interest which they may have (or might be seen to have) in the outcome of any decision in which they are asked to participate. Partners must consider potential conflicts of interest at the earliest stage possible and declare any interest as soon as they realise it is necessary to do so. A partner may be requested to not participate in any decision or perform any other service until the potential conflict is resolved.

Confidentiality Partners must not disclose or make any other use of confidential information to which they have access other than for a proper purpose relating to the performance of services for Trinity Delta or as required by law. Partners must take appropriate steps to ensure that confidential papers and information are stored securely. Partners must promptly notify any breach in confidentiality of which they become aware.

Anti-bribery, gifts and hospitality Partners must not accept any gift, hospitality or benefit from any person which might be perceived as being capable of improperly influencing any decision that may make on behalf of Trinity Delta or any advice that Trinity Delta may provide. Partners are personally responsible for the decision to accept any gift, hospitality or benefit and must ensure that their decisions and advice are not improperly influenced by the promise or acceptance of any gift or other inducement.

Treatment of property Partners should respect and treat properly Trinity Delta’s physical property, IT equipment, communication resources, technology, intellectual property, confidential information, data and any other tangible or intangible assets. These should be used for business purposes and no personal gain is allowed. Partners should ensure that all activities comply with the highest practicable standards of health and safety.

Human rights Partners will uphold all internationally recognised human rights. Partners will not tolerate the use of child or compulsory labour, human trafficking, slavery and any behaviour that does not maintain human dignity and respect. This will apply not only to their activities for Trinity Delta but in their personal dealings too.

Fees and Expenses Partners will be reimbursed for fees and expenses incurred in the performance of their duties for Trinity Delta. These must be reasonable and necessary. Claims must be timely and supported by appropriate invoices, receipts, and relevant documentation. Trinity Delta will seek to ensure that payments are made as soon as practically possible.

Serving for another organisation Partners are encouraged to perform community services, such as working for charities, but their role with Trinity Delta should be considered their primary responsibility. Partners must ensure that no conflict of interest arises with their role with Trinity Delta.

Compliance with rules and regulations Partners are required to comply with all applicable laws, rules and regulations, both in letter and spirit. Any violation, or suspected violation, must be reported as soon as practicable.

Breach of the Code Compliance with the Code of Conduct is a contractual obligation. Minor breaches of this Code will, in the first instance, be dealt with informally by the other partners. Where there is evidence of a serious, deliberate or continued breach of this Code, formal action may be taken against the partner concerned, including termination of the partner’s contract.

Trinity Delta is regulated by the Financial Conduct Authority (Reference number: 725161)