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Disclosure Policy

How do we view Conflicts?

At 5i Research, we are well aware of the potential conflicts in the investment industry. Analysts are conflicted to give a positive view of a covered company so the company is encouraged they do deals with their bank. Advisors can be conflicted due to commissions or pressure to sell their company funds and products. Analysts or writers might be biased due to their ownership of a company or might not talk about a company they own due to the potential restrictions on trading that stock. The only real way around this that we can see is to simply not trade stocks in the market for which you cover. This is why analysts at 5i Research cannot trade in any new Canadian stocks and cannot add to any positions of Canadian stocks. We also do not take payments to cover or issue reports on any companies or funds. Since we still need to be able to invest for ourselves and we love the process of investing, analysts are allowed to trade in ETF’s and/or Mutual Funds traded in Canada as well as securities traded in the US and in international markets (excluding stocks that are cross-listed on a Canadian exchange). So, if we are discussing Canadian stocks at 5i Research, you can be confident that there are no conflicts in the opinion being provided. 

General Disclosure Policy:

  • When a writer or analyst writes a report or article on a stock, ETF, or Mutual Fund, they are to plainly disclose any financial or other interest that they have at the end of the article/report. Please note that a 'financial interest' can include long, short, or some similar exposure through derivative securities (options, etc.).
    • In the case of lists, filters or general headline/news summaries that are done, disclosure of a position is not required (due to the general nature of providing a list) unless the writer specifically addresses a holding within the list that they have an interest in.
    • From time to time, third-parties might provide content to 5i Research. In these cases, they are to disclose any financial or other interest they may have at the time of writing at the end of the content.
    • In general, if a formal opinion or report is published, any positions or interest are to be disclosed at the end of the subject matter.

Disclosures for Canadian Stocks

  • At the end of all formal research reports within 5i Research, members will see disclosure that “Employees of 5i Research involved in the research process cannot trade in Canadian traded stocks and do not hold a financial interest in Canadian companies mentioned”.
    • Due to our conflict policy for Canadian stocks, this should always be the case.
    • If a circumstance were to arise where an analyst holds a financial or other interest in a Canadian stock and discusses it, disclosure of this is required.
      • This circumstance might arise when a new analyst joins the team and is in the process of selling their Canadian holdings.
      • Analysts are encouraged to hold no Canadian stocks upon joining 5i Research but if they do still hold a security, any interest is to be disclosed.
      • Due to past business, 5i Research Founder Peter Hodson owns legacy positions in six Canadian stocks. As long as this is the case, 5i Research will not discuss these securities across any of the 5i services and/or will disclose any interest when applicable.
      • For third parties providing content for 5i Research where they are providing their opinion, disclosure is required.

Disclosures for Non-Canadian traded Stocks (US and International) and Funds (Canadian or otherwise) 

Since analysts are able to trade in non-Canadian markets as well as funds, members need to be aware that conflicts can and will exist if considering any of 5i’s views or opinions on these stocks or funds. From time to time, 5i Research might also have services where non-Canadian stocks are discussed.

  • When a writer or analyst writes a report or article on a stock, ETF, or Mutual Fund, they are to plainly disclose any financial or other interest that they have at the end of the article/report.
  • The analyst who is responsible for and providing the final opinion or view is the one required to make the appropriate disclosure. This means other analysts that were separate from the formulation of any opinion might still hold positions in stocks discussed. If the final opinion writer feels they have been influenced by another analyst who has a conflict, that analysts’ conflict is to be disclosed as well.
  • For the analyst publishing a formal report/opinion and those privy to an opinion before it being published, a 48 hour trade restriction before and after the publish date on the security in question is in place. This restriction does not apply to funds (ETFs, Mutual Funds). 

Disclosures for Affiliated Companies

At times, employees and owners of 5i Research may have a financial interest in affiliated companies which may in turn at times have a financial interest in non-Canadian securities discussed. 

  • When a writer or analyst writes a report or article on a stock, ETF, or Mutual Fund, they are to plainly disclose any financial or other interest that the company may have at the end of the article/report.

Disclosures within the Question and Answer (Q&A) section:

We offer a unique and high value service within the basic 5i Research service where we do our best to leave the question asker with more information on a stock, idea, strategy, etc. than they had before. While the question asker can be confident that there are no conflicts for Canadian stocks discussed, they need to be aware that when asking any questions on Funds and/or non-Canadian traded investments; there might be a conflict. To address this, every e-mail response includes a note that we 'may hold a financial or other interest in funds or US and international securities mentioned’. Further, if an author or owner/director holds a position in a mentioned security at that time, it will be plainly disclosed at the end of the question as:

Authors of this answer, directors, partners and/or officers of 5i Research have a financial or other interest in X, Y, Z at the time of answering this question.

Some things to keep in mind:

  • Questions are submitted by the member where an opinion is being requested. 5i Research is not soliciting the opinion in any formal way.
  • These answers (or anything contained within 5i websites) are opinions only and not financial advice and should not be construed as such. Do your own due diligence and/or consult a financial advisor before taking any investment action.
  • We do not want a member to misconstrue any interest in a security to mean it is appropriate for a general audience or that it might be a holding that we have a high opinion of, regardless of the answer provided. We do not know who is asking the question and the member may have a very different situation than the analyst. Essentially, we do not want members to try to read between the lines, especially since there may be nothing ‘between them’.
  • While we do our best to keep these disclosures up to date and comprehensive, errors can happen from time to time and members need to understand that errors or omissions can occur. If errors are found, 5i Research will take the appropriate measures to fix any error.

Trading Restrictions

The trading restriction for Canadian stocks is that analysts at 5i Research are not allowed to trade in Canadian stocks.

In the rare cases previously mentioned for legacy positions and/or new employees in transition, if they provide an opinion or report on a Canadian security with which they are exposed, they are to disclose it (as previously mentioned) and also not sell any shares within a 48-hour period (48-hours means business days only, not weekends when markets are closed). 

From time to time, 5i Research might offer formal opinions or reports on US or International stocks or offer services that discuss non-Canadian stocks. For these reports where a formal opinion is being presented, any interest in the holdings are to be disclosed as of the publishing date. The publishing analyst is restricted from trading in securities discussed where a formal report is being published within 48 hours (two business days) before and after the report is published.

There may be situations where an analyst has given discretionary authority to another party for the management of their portfolio. In these cases, there are no restrictions on the trading of non-Canadian securities but the publishing analyst still cannot direct the manager to make changes within the 48-hour period. 

If an editor has become privy to information such as a formal opinion, they are also restricted from trading in the holding within 48 hours of publishing.

We do not require trading restrictions on ETFs or Mutual Funds.

Finally, we do not have trading restrictions for non-Canadian stocks that are addressed inside of the Q&A section. We answer numerous questions daily and requiring a restriction would simply be too onerous of a request for analysts at 5i Research. Any financial interest, however, is disclosed at the time of answering a question.


We hope you find this document to be transparent and helpful in understanding our disclosures. While we do our best to ensure the appropriate disclosures are made at all times, there is always potential that a disclosure gets missed and we will do our best to rectify the situation. However, like always, the member or user of the web site is still responsible for their own decisions when making investments and disclosures do not limit this responsibility. 

We are happy to receive feedback on this document at