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GLG’S ROBUST COMPLIANCE FRAMEWORK


 * INTRODUCTION
   
   As the category pioneer, GLG has led the industry in the establishment and
   development of compliance standards for expert networks. Compliance is
   foundational to our business and our culture. Our unparalleled compliance
   systems and technologies provide a structured, auditable, and transparent way
   for our clients to receive actionable insights in a manner that is consistent
   with the highest professional standards and best practices.
   
   GLG clients value our experts for their knowledge and insights, but they also
   recognize and respect that there are certain constraints on the information
   our experts can share. Over the past decade, we have dedicated considerable
   financial resources and thousands of hours to creating the most
   technologically advanced and comprehensive compliance system in the industry.
   This system, and its associated compliance protocols, help experts to manage
   conflicts and facilitate coordination with our clients’ own internal
   protocols. Our compliance framework is a major competitive differentiator.
   
   GLG’s Compliance team comprises more than 50 professionals. It is led by our
   General Counsel, Laurence Herman, who has nearly two decades of industry
   experience, and our Chief Compliance Officer, Jonathan Scott, who has 13
   years of regulatory experience.
   
   If you have any questions about compliance at GLG, please email
   compliance@glgroup.com or call 512-651-3700.


 * FOR NETWORK MEMBERS
   
   Contracts
   To be eligible to consult, GLG requires experts to sign, and annually
   re-sign, our terms and conditions, agreeing that they:
   
    * Have reviewed any relevant agreements to which they are subject and are
      permitted to serve as experts;
    * Will decline to participate in any project that would violate those
      agreements or any obligations they may owe to third parties;
    * Will not provide confidential (including material non-public) information
      to clients;
    *  Will keep client interests and information confidential; and
    *  Will immediately terminate any consulting project that moves into subject
      matters they cannot discuss (in which case, if they notify us, we’ll pay
      them for the time they set aside).
   
   View the current Terms and Conditions.
   
   Training
   Experts are also required to complete GLG’s proprietary, interactive tutorial
   each year. The tutorial is sector-specific (e.g., healthcare experts receive
   different training than tech experts), and each module is available in 20
   languages. The training branches depend on the expert’s specific background
   within their sector. The tutorial explains what constitutes “confidential
   information,” and sensitizes experts to any confidentiality obligations they
   may have. Experts are reminded at the outset of every engagement that clients
   would be harmed if they were to receive confidential information and that
   even inadvertent disclosures of such information could require our investment
   clients to discard countless hours of research and/or freeze positions.
   
   Conflict Management
   Experts often have conflicts. At GLG, we actively seek to identify expert
   conflicts and use this information to disqualify experts from projects on
   which they are conflicted or otherwise unsuitable. Among other important
   steps, in connection with projects, we ask Profile Questions that help us to
   understand the experts’ conflicts and limitations and determine whether
   experts have the requisite knowledge to provide insight to clients. GLG’s
   robust screening of active Network Members supports the quality and integrity
   of our platform. Millions of answers to our screening questions are stored on
   our systems, giving us unparalleled information on expert conflicts and
   abilities. And we leverage our trained professionals to help experts navigate
   potential conflicts and to clarify our expectations for participation in GLG
   projects. Experts are instructed to terminate any project that unexpectedly
   presents a compliance issue for them and that, regardless, they will be paid
   for the time they set aside.


 * FOR CLIENTS
   
   GLG’s compliance systems help protect our clients by mitigating the risk of
   inadvertently soliciting or receiving confidential information from our
   experts and controlling the type of client information that is shared with
   experts. Our custom controls help to screen and manage expert engagements and
   avoid connecting clients with experts who may be conflicted or are prohibited
   from consulting by their employers.
   
   We developed our web-based Project Oversight tools to enable clients to
   monitor their primary research activity in real time and implement their own
   protocols for engagement with experts.
   
   Through our compliance “dashboard,” client oversight personnel can view their
   firm’s primary research activity in real time, including relevant information
   about experts (e.g., biography, responses to GLG profiling and client’s own
   oversight questions, and information regarding the experts’ prior
   interactions with the client). From the dashboard, oversight personnel can
   implement rules directed toward certain populations of experts. For instance,
   they can hardwire the dashboard so their compliance teams are notified of or
   have the opportunity to pre approve consultations based on a number of
   criteria. Clients can also establish custom screening questions or
   attestations to support compliance. Each expert must review and respond to
   these screens prior to participating in a consultation with any client user.
   Clients can tailor questions to an individual’s area of expertise.


 * FOR EMPLOYERS
   
   GLG’s compliance framework takes into account any constraints an employer may
   place on its employees’ ability to serve as experts. Employed experts are
   prohibited from participating in projects about their employer. Additionally,
   to engage in written, in-depth and/or ongoing projects, employed experts
   (other than those who qualify for an exemption based on their status) must
   obtain written confirmation of employer consent. GLG also manages a database
   of employer preferences to help enforce restrictions organizations may have.
   
   If you’re an employer and want to inform us of any policies you have
   regarding outside consulting, please feel free to do so by emailing us at
   compliance@glgroup.com or calling +1 (512) 651-3700.

We bring the power of insight to every great professional decision.

 * Clients
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     * Technology
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