Research Independence Policy

Smallcaps Research is distributed through Smallcaps and produced by investhouse.ai. InvestHouse is a business operated by Volatility Pty Ltd. Volatility is a Corporate Authorised Representative of Point Capital Group Pty Ltd, holder of Australian Financial Services Licence No. 518031.

Purpose

This policy summarises the arrangements used for Smallcaps Research produced by investhouse.ai to support research integrity, objectivity, and clear disclosure of conflicts.

It is designed with regard to ASIC guidance for sell-side research, including the principles reflected in Regulatory Guide 79 and Regulatory Guide 264.

Scope

This policy applies to investment research, research notes, issuer commentary, valuation material, and related report content prepared for publication or distribution through Smallcaps, investhouse.ai, or related Volatility platforms.

It applies to research authors, reviewers, editors, product staff, and any person involved in preparing, reviewing, approving, publishing, or distributing research.

Research Responsibility

Research authors are responsible for preparing fair, balanced, and supportable analysis based on available information, stated assumptions, and clearly identified limitations.

Smallcaps Research uses a combined AI and analyst-review pathway. Automated tools, quantitative models, and AI-assisted drafting may support data extraction, summarisation, modelling, editing, and report structuring, but the final research output remains subject to analyst or author review before publication.

Research Reports

Research reports should distinguish facts from opinions, forecasts, estimates, price targets, and valuation judgements.

Recommendations, ratings, valuations, and target prices must be supported by a stated basis and should not be influenced by corporate advisory, capital markets, investor relations, media, or commercial services provided by Volatility or its related entities.

Publicly Available Information

Research is generally prepared from publicly available information, issuer disclosures, market data, and other sources believed to be reliable at the time of publication.

Research must not be published where the author or reviewer is aware that the report depends on material non-public information. Any suspected inside information issue must be escalated before publication.

Conflicts of Interest

Volatility, its related entities, officers, employees, contractors, or associates may provide or seek to provide services to companies mentioned in research, including corporate advisory, capital markets, investor relations, media, consulting, or other commercial services.

Potential conflicts must be identified, managed, and disclosed where relevant. Research should include general conflicts wording and any specific disclosure required for a known material relationship or interest.

Research Independence

Research conclusions, ratings, valuations, and price targets should reflect the author's genuine analytical view and should not be subject to approval by a covered issuer or by commercial teams seeking a favourable outcome.

Draft research may be checked for factual accuracy where appropriate, but valuation, rating, recommendation, and price target content should not be provided to the subject company for approval before publication.

Capital Raising and Advisory Activity

Where Volatility or a related entity is involved in capital raising, corporate advisory, or other transaction activity, research staff and reviewers must take care to avoid improper influence, selective disclosure, and the use of non-public information.

If a person involved in research is wall-crossed or otherwise receives inside information, they must not prepare, influence, or publish research commentary about the affected issuer until the relevant information is no longer inside information and any required review has occurred.

Research Funding and Remuneration

Research authors' views should not be tied to specific corporate advisory revenue, transaction outcomes, or the commercial preferences of covered issuers.

Any compensation arrangements that could reasonably be perceived to affect research independence should be managed and disclosed where required.

Coverage Decisions

Decisions to initiate, maintain, suspend, or cease coverage should be made having regard to investor relevance, availability of reliable information, research capacity, and conflict management considerations.

Coverage decisions should not be used to promise favourable treatment to an issuer or as an inducement connected with corporate advisory or capital markets work.

Disclosure

Research reports should include clear disclosure of the publisher, general-advice basis, conflicts, analyst certification, AI assistance where relevant, jurisdictional restrictions, copyright, and any known material issuer relationship or interest.

Readers should also consider the Volatility Financial Services Guide and the disclaimers included in each research report before acting on any information.