AGI Compliance Management System
Astute Global Infoservice Company Limited is dedicated to providing our clients with a safe, confidential, and risk-free platform for the exchange of knowledge. Our comprehensive compliance policies are supported by training, audits, and clear escalation procedures to proactively reduce the risk related to confidential and potentially material, non-public information and other compliance-related risks. The compliance controls are reviewed and updated by the AGI's in-house Legal and Compliance team on an ongoing basis, and verfied via annual external audits to ensure the system remains robust at all times.
Our compliance system faces the key stakeholders of our business - employees, expert consultants, and clients - and is in line with up-to-date U.S Securities Laws, anti-corruption and anti-money laundering,regulations and compliance best practice.
Please click on the icons below for more details on each pillar of our compliance program.
- Compliance Protocols
- Expert Compliance
- Client Compliance
- Compliance Monitoring
AGI's expert referral process is governed by a set of clear, easy to understand Compliance Protocols that is reinforced by ongoing training and spot checks. According to the protocols, each team leader and project manager has the duty to:
• Take responsibility for compliance risk management of their projects
• Follow AGI's internal and Client compliance protocols at all times
• Review projects for potential sensitive topics or conflicts of interest
• Escalate any potential issue to AGI's Legal and Compliance Team
• Confirm adherence to the above protocol before scheduling an Expert Consultation
Failure to adhere to AGI's compliance protocols - either willfully or through negligence - could lead to disciplinary action, up to and including dismissal.
Training is central to AGI’s compliance management system to ensure we have a culture of compliance that is prevalent throughout the organization. Our employees therefore receive compliance training when joining the company and quarterly thereafter. Each year their compliance knowledge is tested at least twice and this forms part of their performance review.
To further support our compliance goals, all employees are required to:
- • Agree to AGI’s Insider Trading Policy and adhere to our security investment policies
- • Agree to the firm’s Proprietary Information and Inventions Agreement and adhere to the strictest confidentiality
- • Attend on-board and quarterly in-house compliance training
- • Act in a legally compliant and ethical manner at all times
During the expert recruitment stage we have the following minimum checks and balances in place. As such all experts must:
• Be qualified by our recruiter team upon joining our network
- • Complete a compliance training session at the point of verification
- • Agree to our formal Terms and Conditions
- • Reaffirm and reaccept AGI’s T&Cs and online compliance training program every 12 months
Additionally, the experts receive a compliance reminder when being scheduled for a consultation with AGI clients. Our experts are actively encouraged to refrain from answering questions that are deemed too sensitive, or in violation of ethical, contractual legal and regulatory obligations that they might have.
We pay all experts a set rate based on the time of the phone call, including when the call is terminated early due to compliance issues.
Expert Terms and Conditions
All experts are required to sign industry-standard Terms and Conditions and undergo annual compliance training before being allowed to participate in AGI’s Expert Network. During this process the following key aspects of AGI’s commitment to ethical conduct and legal compliance are highlighted:
• Duty and obligation not to disclose Material Non-Public Information, Trade Secrets, Proprietary Information and Intellectual Property
• Obligation to refrain from violating laws and duties to Third Parties
• Decline participating in projects that constitute a Conflict of Interest
• Decline projects where topic is expert’s current employer or where the client is a direct competitor of the expert’s employer
• Refrain from giving investment, legal, or medical advice
Experts are required to notify our project managers of any non-disclosure agreements or potential conflicts of interest arising from a consultation – prior to being linked to our clients.
Expert T&Cs Expert Tutorial
AGI’s compliance policy is dedicated to supporting and enhancing the compliance beliefs of our clients while reducing client exposure to regulatory risk. Our compliance mission is to ensure a confidential and legally compliant client service, while safeguarding against the dissemination of sensitive information like trade secrets, material non-public information, and other restricted information and data.
Complementary to our internal compliance systems, AGI is able to implement special client compliance requirements during the Expert Referral process. Our Project Managers and Compliance Staff routinely assist clients in honoring the following compliance requests:
• Pre-consultation screening questionnaires
• Obtaining a pre-call approval from client compliance team
• Regular Usage and Compliance Reports on request: Weekly, Monthly, or Quarterly
• Public company alerts
• No exchange of personal contact information
AGI maintains a database of special protocol that guides expert referrals for each client, e.g. no current employees of target listed companies, at least 6 months resignation. These client protocols are backed up by a Compliance Checklist that each project manager is required to follow during the referral process, with a formal compliance sign-off obtained from project managers before each call is made.
Consultation Oversight Capabilities for AGI Customers
Compliance products available on request to client administrators:
- • AGI staff can keep client compliance team up to date with the expert referral process via email and send expert details to client compliance team for pre-consultation approval.
- • AGI allows client compliance teams to sit in on calls as they see fit to monitor information shared with their users.
- • Clients can monitor research activity via expert usage reports at any frequency required, i.e. monthly or quarterly.
AGI complies with the Anti-Corruption Practice Act (ACPA), AML and Office of Foreign Assets Control (OFAC) regulations, while avoiding doing business with individuals on the SDN list maintained by OFAC and the U.S. Treasury. To effectively identify and manage potential risks, we have the following internal procedures in place:
• Project Screening: AGI department managers screen and either approve safe projects or eliminate sensitive projects during initiation stage;
• Compliance Checklist: Our Projects Managers are required to adhere to a set of critical compliance requirements when referring experts to clients and have to give a
final pre-call acknowledgement that they have taken all reasonable care to follow the related AGI and client compliance;
• Internal Compliance Auditing: AGI’s Compliance Team does ongoing daily Compliance Audits along the entire extent of the Expert Referral cycle, from initiation to sending out the final Dial-In Schedule. In this way we can monitor Project Managers’ compliance to the checklist, as well as identify and eliminate potential compliance breaches;
• Do-Not-Call List: We maintain and update a DNC for companies that prohibit their employees from being a third-party consultant.
Ongoing Internal Compliance Audits & Review
AGI has implemented an ongoing Internal Compliance Auditing System to identify compliance risk areas and manage risk trends among employees, clients, and experts (e.g. a breach log). Furthermore, the ongoing audits aim to measure whether and how effectively the relevant internal and external compliance controls are followed by AGI staff, experts and users. Each month the data is analyzed by the AGI Compliance Team and an audit review is held with the company founders.
Audit Target Areas:
- 1.Emails – all expert referrals are copied to AGI compliance mail group and reviewed by AGI's compliance team
- 2.Compliance checklist for project managers
- 3.Pre-call compliance sign-off for experts
- 4.Post-call feedback from experts
- 5.Client usage reports