Origin Compliance Policy Framework

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An Overview of our Strategic Compliance Safeguards

1. Overview of the Origin Product
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Each Origin Snapshot is an outside-in, syndicated summary that synthesizes publicly available information with thematic or generic company insights gathered through interviews with industry experts. These interviews are conducted exclusively by Dialectica’s internal team and governed by a robust set of compliance controls.


2. Expert safeguards and anonymous engagement
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Experts who contribute to Origin Snapshots are subjected to a thorough screening process designed to minimize the risk of material nonpublic information (MNPI) being shared during the interview. In particular:
● Current employees of the subject company are prohibited from participating in Origin interviews.
● Current employees of publicly traded companies may participate in Origin interviews if their current employer is not the target company but are precluded from discussing their current employment.
● Former employees of publicly traded companies are subject to embargo periods where applicable.
●All Experts formally agree to Dialectica’s Terms of Engagement, which include prohibitions against sharing MNPI and other confidential information.
●Experts are reminded of these obligations at multiple stages: onboarding, screening, and immediately prior to each engagement.
●Every interview follows strict anonymity protocols. Dialectica takes all reasonable steps to maintain complete confidentiality of Experts' identitiesthroughout the process.

3. Internal controls during the interview process
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Origin interviews are conducted by Dialectica’s internal Origin Team, which is trained on all relevant compliance policies and procedures. Specifically, these team members receive regular instruction and testing on topics such as MNPI, insider trading, and conflicts of interest.To mitigate risk further:
● Interviewers use pre-approved discussion guides, which are drafted incoordination with Dialectica’s Legal & Compliance Team, to avoid topics that may elicit MNPI or otherwise sensitive information.
● The process is designed to generate high-level insights that do not pose compliance risks.


4. Three-step review process

Every Origin Snapshot undergoes a thorough three-step review prior to being shared with clients:

Step 1: Initial Origin Team ReviewThe Snapshot is first reviewed and anonymized by the Origin Team, who ensures that all insights are presented in a generalized manner, free from company-sensitive information or identifiable data. This step includes formatting, standardization and removal of any potentially sensitive references.

Step 2: Legal & Compliance ReviewThe Snapshot is then reviewed by a team within Dialectica’s Legal & ComplianceDepartment that is dedicated to the Origin compliance process. This team assessesthe content line-by-line for any risk of MNPI and/ or confidential information, ordeviations from Dialectica’s internal policies. Particular review is applied to ensurealignment with relevant legal frameworks governing market conduct, including rulesrelated to insider information. This review serves as the primary compliance safeguardand represents a formal clearance point before the document proceeds to QualityAssurance Review (QA).

Step 3: Quality Assurance ReviewThe Origin QA function, consisting of senior and experienced Origin members and reporting to the Director of Origin, conducts a comprehensive review for residual compliance risks, clarity, and editorial consistency. This team’s role is to confirm that all compliance protocols have been followed and any compliance notes have been incorporated. The Origin QA function provides the final approval, ensuring that eachSnapshot meets Dialectica’s standards for accuracy, quality, and compliance.Through this multi-layered and interdependent process, we aim to ensure that everyOrigin Snapshot is actionable and safe to use.


5. Innovation and Technology

As part of our ongoing commitment to operational compliance innovation, Dialectica has integrated a custom-built AI-supported tool into the Origin Snapshot review process. This solution was developed by Dialectica’s Legal & Compliance Departmentand Data Science Team to help identify high-risk content, such as potential MNPI, confidential information, or personally identifiable data, during QA review. This combination of human- and machine-led processes enhances each process and reinforces our ability to deliver content that is both actionable and safe.


6. Dedicated Compliance & Legal Team for Origin

A dedicated Compliance Team for Origin has been established to support the unique needs of the Origin product. The team is responsible for the handling of all legal and compliance matters, including cross-departmental compliance training, real-time compliance QA of Origin Snapshots, expert compliance adherence, policy documentation, client compliance requests, and privacy issues, among other things.This specialized team operates with deep knowledge of Origin’s risk profile, regulatory environment, and market standards, ensuring that every interaction meets the highest level of compliance integrity.