Legal
Research Independence Policy
Last updated: 10 September 2025
Our commitment
Banyantree Investment Group Pty Ltd (ABN 97 611 390 615, AFSL 486279) prepares research with integrity and independence. We maintain arrangements to identify, control and, where needed, avoid conflicts of interest, consistent with our obligations as an AFS licensee.
Purpose and scope
This policy sets the standard for all research and commentary we author or distribute, including practitioner notes, market views, issuer or sector pieces, and investor education materials. It covers our people and representatives involved in research creation, review, approval and distribution. It should be read alongside our Conflicts of Interest Policy, Privacy Policy and Complaints & IDR Policy.
Independence principles
We follow these principles:
Investor first: research is prepared for the benefit of clients and readers.
Separation: decision-making is insulated from commercial, corporate, banking or distribution pressures.
Transparency: material interests and relationships are disclosed clearly and on time.
Evidence: views are supported by stated methods, sources and risks.
Control: when conflicts or inside-information risks arise, we apply effective barriers or step aside.
How we manage conflicts in research
We use a structured approach—identify → assess → control → review.
Controls include: avoidance, segregation and information barriers, pre-clearance/supervision, and prominent disclosure. We keep auditable records.
Information barriers & non-public information
Where there is a risk of access to non-public or transaction-sensitive information (e.g., capital raisings, market soundings, wall-crossings), we apply need-to-know access, restricted lists and trading halts for covered securities. Analysts must not use or share inside information.
Analyst conduct, remuneration and interests
Analysts certify that views are their own, made free from undue influence.
Analyst remuneration is not linked to specific corporate transactions or issuers covered by their research.
Personal Account Dealing rules apply (pre-clearance, blackouts, holding periods, restricted lists).
Gifts/benefits above thresholds are prohibited and all permitted hospitality is recorded.
Interactions with issuers and corporate teams
Contact with issuers is chaperoned or logged and limited to appropriate topics.
Issuer review (where offered) is for fact-checking only—not opinions, recommendations or price targets.
During capital raisings, additional controls apply to investor education and any research production.
Research creation and approval
Methodology: Each report states key assumptions, valuation methods (if used) and principal risks.
Disclosures: We include clear disclosures of material interests or relationships relevant to the issuer or subject.
Reviews: Content, disclosures and conflicts are reviewed by Compliance where appropriate before release.
No selective disclosure: Research is released simultaneously to intended recipients; no early access for preferred clients.
Ratings and recommendations (if used)
If we use ratings or recommendations, we publish the rating definitions, any price target basis (if applicable), and—where relevant—distribution statistics over a rolling period. We avoid rating changes that could be perceived as transaction-driven.
Corrections, updates and retractions
Where a material error is identified, we issue a correction or retraction promptly and explain what changed. For time-sensitive pieces, we may publish updates when assumptions or signposts change.
Third-party research
If we distribute third-party research, we do so under licence, monitor provider standards and disclosures, and apply our own conflicts checks before circulation. Where appropriate we add our own disclosure wrapper.
Record-keeping
We maintain records of drafts, approvals, disclosures, distribution lists, source data (where practicable) and any issuer review comments for the periods required by law and our AFSL.
Training and attestations
Research staff complete initial and periodic training on conflicts, inside information and this policy, and provide annual independence attestations. Breaches are escalated to Compliance and, where required, reported under our breach reporting framework.
Audience and suitability
Unless stated otherwise, our research is general information and does not take into account your objectives, financial situation or needs. Where specified, certain publications may be intended for wholesale/professional investors only.
How to raise a concern
If you believe a report is not independent, contact us via the details on our Complaints & IDR Policy page. If you are not satisfied with our response, you can escalate to AFCA (free and independent).
Review cycle
We review this policy at least annually and sooner if our business model or the regulatory environment changes.