Trading & Information Policy

Walter receives investment-newsletter content — including specific, potentially market-moving recommendations — at the moment of ingestion, before or as subscribers act on it, and computes ratings analytics before they are published. Trading on that stream, or tipping it, would expose Walter and the individual to insider-trading liability under the misappropriation theory, would destroy the independence on which the Walter Grade rests, and would fail any investor or partner diligence review. This Policy makes the commitment operational and auditable: no person at Walter trades on what Walter sees before the market does.

All Walter employees, officers, founders, contractors, advisors, and agents with access to ingested newsletter content, the position ledger, the parse pipeline, pre-publication scores or grades, or subscriber activity data — expressly including the CEO, the engineering co-founders, the CGO, and any automated or agent-operated system acting on company credentials. Covered Persons are responsible for accounts they control or influence, including accounts of household members.

(a) Ingested newsletter content from any source — the ingest relay, user-linked inboxes, Walter-held subscriptions, or archive backfill — until its derived data is eligible for public display under Walter's display policy; (b) unpublished scores, grades, classifications, and grade changes prior to their scheduled publication; (c) aggregate subscriber flow or engagement data; and (d) any other material non-public information obtained through Walter systems. Public availability of the underlying newsletter to its own subscribers does not make the information public for purposes of this Policy.

No Covered Person may (a) buy, sell, or otherwise transact in any security, derivative, or crypto asset that is the subject of Covered Information, or in the governed proxy instrument for a covered directional concept; (b) tip, forward, or disclose Covered Information outside Walter systems; (c) trade on unpublished grade or score movements; (d) use subscriber activity data to inform any trade; or (e) accept gifts, entertainment, or anything of value beyond nominal amounts from any rated publisher, marketplace partner, or affiliate. The prohibitions in clause (a) run from ingestion receipt until the later of the content's public-display eligibility under the display embargo or two full trading days after receipt.

Persons with pre-release access to grade computations may not trade in securities held or newly recommended by newsletters in the affected peer groups from the data-lock preceding each scheduled grade refresh (the 1st and 15th of each month) until publication. Staff involved with Walter's internal testing publications may not trade ahead of those publications' test sends.

Broad-based index funds and diversified ETFs or mutual funds; transactions under pre-existing automatic plans (retirement contributions, dividend reinvestment, scheduled purchases) established before access to Covered Information; and transactions pre-cleared under Section 7.

Any transaction in an individual security, single-name derivative, or crypto asset by a Covered Person requires written pre-clearance before execution. The Chief Executive Officer clears requests from Covered Persons; the General Counsel clears requests from the Chief Executive Officer. Clearance is valid for two trading days and is never granted where the instrument is the subject of Covered Information.

Covered Persons disclose brokerage and crypto accounts under their control at onboarding and upon opening new accounts, and certify compliance with this Policy quarterly. Attestation is part of onboarding. Records are retained by the General Counsel.

Access to ingestion, the ledger, and pre-publication analytics is least-privilege and logged. Automated and agent-operated systems hold no brokerage capability, execute no transactions, and do not transmit Covered Information outside Walter systems. Access logs are reviewable in any investigation under this Policy.

If and when affiliated brokerage services launch, this Policy is supplemented by broker-dealer-grade compliance procedures, including information barriers between the ratings pipeline and any execution business. Nothing in this Policy authorizes proprietary trading by Walter or any affiliate on Covered Information under any circumstances.

The General Counsel administers this Policy, reviews it annually, and may grant no exception inconsistent with Section 4. Violations are grounds for discipline up to and including termination of employment or engagement, and referral to authorities where warranted. Publishers' own trading conduct is governed by their obligations and the representations in their Walter agreements; this Policy governs Walter personnel and systems.