As of September 19, 2026
This policy describes how Montega AG identifies, prevents, manages and discloses conflicts of interest in connection with issuer-sponsored research. It is based on Commission Delegated Regulation (EU) 2026/1092, hereinafter referred to as the “Regulation”. The policy applies to employees and members of the Management Board to the extent that their activities or access to information may affect research.
The detailed operational requirements are implemented through internal policies, process descriptions, and work instructions. These provide concrete details for the present strategy and must not undermine its security requirements.
1. Responsibility and Independent Decision-Making
The Management Board approves the policy and ensures that adequate resources are made available. The responsible compliance function assesses conflicts of interest, determines appropriate safeguards, maintains the conflicts register and investigates potential breaches. Relevant persons are required to report relevant interests, changes and suspected breaches without undue delay. No person may approve their own transactions or make the final decision regarding a material conflict affecting themselves; where necessary, a suitably qualified and impartial substitute is appointed.
2. Identification and Management of Conflicts of Interest
Existing and potential conflicts of interest are identified when a mandate or research assignment is taken on and whenever relevant circumstances change. Relevant factors include, in particular, issuer funding, other business relationships including those involving affiliated entities, revenue dependencies, remuneration incentives, personal and relevant family interests, shareholdings, dual roles and attempts to influence the research process.
All identified existing and potential conflicts of interest, together with the measures taken to prevent or manage them, are recorded on an ongoing and up-to-date basis in the conflicts register. Depending on the nature and level of risk, access may be restricted, responsibilities segregated, independent reviews arranged or affected persons removed from the relevant activity. Required disclosures are made. Where a conflict cannot be adequately managed despite these measures, the affected activity is suspended until the conflict has been resolved.
3. Independence and Information Safeguards
Research outcome and remuneration: Montega does not promise research or recommendations favourable to the issuer and does not permit any direct or indirect influence by the issuer or persons acting on its behalf over the content or outcome of the research. Remuneration must not be linked, directly or indirectly, to the content of the research. The same requirements regarding analyst qualifications, resources and the nature of the research content apply to issuer-sponsored and non-sponsored research.
Dual roles: Analysts are generally not directly or indirectly involved in commercial solicitation or contractual negotiations with an issuer they cover. Interactions required to enable the issuer to assess an analyst’s professional expertise in a particular area remain permissible. Where such segregation of duties would be disproportionate in view of Montega’s size, organisation or business activities, the reasons and appropriate measures to prevent or adequately manage the resulting conflicts of interest are documented. Pricing and contractual decisions, as well as any required independent professional reviews, are assigned to suitable persons who are not affected by the relevant conflict.
Information barriers: Research analysts are physically separated from persons whose responsibilities or business interests may conflict with those of the research function or, where such physical separation would be disproportionate in view of Montega’s size, organisation or business activities, appropriate alternative information barriers are maintained. These include, in particular, role-based access rights and the segregation of confidential research information from transaction-related information. This also applies in relation to affiliated entities. Potential inside information must be reported without undue delay to the responsible compliance function, which assesses any required trading, access or participation restrictions.
Issuer review: Any factual review by the issuer is carried out only on the basis of a version that does not contain the investment recommendation or target price. Drafts containing an investment recommendation or target price must not be provided to the issuer or other relevant persons outside the analyst function for the purpose of reviewing factual information, unless such review is conducted solely to verify compliance with legal obligations. The issuer has no right to approve or require changes to investment recommendations, target prices or other analytical conclusions.
4. Personal Transactions
Analysts and other persons involved in the preparation of issuer-sponsored research are subject to specific trading restrictions in respect of the financial instruments covered by the research and related financial instruments. Relevant holdings and interests must be disclosed in accordance with the applicable internal requirements.
Any person who has knowledge of the expected timing or content of research which is not yet public or otherwise available to the intended recipients and cannot readily be inferred from available information must not trade, either personally or on behalf of another person, in the relevant or related financial instruments until recipients have had a reasonable opportunity to act on the research.
Even outside such circumstances, personal transactions and other trading by analysts and other persons involved in the preparation of the research in the relevant or related financial instruments are generally prohibited. Exceptions are permitted only in exceptional circumstances and with the prior approval of an impartial person within the Legal or Compliance function. Any further statutory or internal trading restrictions remain unaffected.
5. Disclosure of Conflicts of Interest
Existing and potential conflicts of interest are disclosed in accordance with applicable legal and regulatory requirements. Issuer-sponsored research contains the required disclosures, in particular regarding relevant interests, business and contractual relationships and revenue-related conflicts of interest. Such disclosures are reviewed for accuracy and currency prior to dissemination.
6. Violations and Effectiveness Review
Where Montega becomes aware of or identifies a potential breach of this policy, Montega investigates the matter and informs the affected issuer without undue delay of the potential breach and of the measures taken to prevent, remedy where necessary, or otherwise appropriately manage the breach.
The responsible compliance function assesses and reviews this policy regularly, and at least annually, as well as following material changes or identified deficiencies. Material deficiencies are appropriately remedied and any necessary amendments to the policy are duly approved. The published version is kept up to date.
Contact: compliance@montega.de