Integrity, ethical behavior, and professional excellence are the core principles guiding the research process at Blue Heron Research Partners.
Comprehensive compliance program
Blue Heron’s compliance policies and operating procedures are designed to parallel the relevant aspects of our clients’ compliance programs. Our compliance infrastructure is designed along three dimensions:
Our business practices have been designed with input from outside counsel and client CCOs to ensure that our research gathering process and operations comply with all applicable regulatory and legal requirements.
These policies and procedures undergo periodic reviews by outside counsel and are subject to ongoing client DDQ processes. To ensure compliance in all applicable areas, we have sought specialized counsel on: MNPI, Pre-Employment and FCRA, GDPR, Consumer Privacy, Jurisdictional Questions, and International Laws.
Meeting client expectations
We ensure that our research-gathering process is consistent with our client expectations, and that all the research we deliver has been carefully reviewed for compliance-related concerns that could compromise a client’s ability to make an investment.
All employees participate in ongoing education, including training in how to identify MNPI. Our internal escalation procedure ensures that potential issues are reviewed by our compliance team, who will engage with client investment teams and/or compliance teams as appropriate to vet content.
Internal compliance guidelines
To ensure the highest standards of professionalism in our staff, Blue Heron maintains internal compliance guidelines, which include a compliance manual, employee handbook, and an ethics and professional conduct policy.
Our compliance program is administered similarly to how our clients might approach this important function with ongoing reviews, internal testing and controls, and formal documentation. We also conduct training at the functional and department level on an ongoing basis. All staff are required to re-acknowledge the compliance manual and employee handbook annually.