GLG’s Robust Compliance Framework

1. 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.

If you have any questions about compliance at GLG, please email compliance@glgroup.com or call 512-651-3700.

2. 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.

3. 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.

4. 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.

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