Capstone sets the standard for creating and adhering to a set of compliance principles that protects our clients and our business. Though we believe a system of clear rules, consistent supervision and regular education are important elements of a good compliance plan, we do not believe these guidelines are a substitute for creating a strong culture of ethical behavior.
Capstone Compliance Highlights:
Capstone does not operate an expert network business model. Our core product is the analysis of our investment professionals. We do hire experts from time to time, but these interactions are strictly controlled. Capstone employees are prohibited from compensating government officials (federal, state, local or foreign) in any way for meetings, conversations or other interactions. Capstone employees are prohibited from compensating any person who has been a government official (federal, state, local or foreign) within the last six months of when the payment is made. Capstone employees are prohibited from compensating any current employees of a publicly listed company or any person who has been an employee of a publicly listed company within the last 12 months of when the payment is made. Capstone employees must clear compensation for other sources (lawyers, outside experts, etc.) with the chief compliance officer.