Compliance is at the core of NewtonX products and services

The line of business in which we operate is one of the most differentiating and sensitive ones in today’s world. Knowledge is the most valuable asset to NewtonX’s clients: it adds tremendous value to their business, but it can also destroy value if handled incorrectly. Leveraging our long-standing experience in the industry as well as a close collaboration with our clients, we have developed a compliance framework that is not only one of the most conservative and robust in the industry, but is also reinforced by our search algorithm which ensures compliance by not matching professionals to customers where potential compliance issues could arise.

The NewtonX compliance framework

We have designed our framework with the objective of ensuring compliance from both the professional and client point of view. Our compliance framework relies on three principles that guide NewtonX’s professional conduct.

• Conservative
  We prefer to consistently choose the most conservative and secure line of conduct rather than approach any grey area from a compliance or legal standpoint. When in doubt, we would rather not let a professional share his or her expertise than create any risk for the professional or the client.
• Proactive
  We do not rely on our professionals and clients just “knowing the rules” and signing the compliance terms. Our long experience in the industry has taught us that constant vigilance and proactivity are the key to success to avoid any glitch in even the most robust compliance framework. This is reflected in our interactive compliance tutorials we give our professionals as well as our employers’ preferences database.
• Transparent
  We pride ourselves in having a superior product that makes expertise sharing more efficient and transparent. The same transparency applies to our compliance processes. Feel free to contact us for any questions or to request any compliance documentation at compliance@newtonx.com

Professionals receive compliance training and are bound by the NewtonX terms and conditions.

Screening and selection

We select our professionals with extreme care and attention. Each professional goes through a very selective evaluation and vetting process which:

• Validates their identity based on public sources as well as their personal identification.
• Granularly assesses their areas of expertise in order to guarantee accurate matches with the expertise requests from our clients.
• Ensures a granular mapping of their previous employers to accurately avoid any conflict of interest.

Professionals’ terms and conditions

In order to be accepted on our platform and share expertise with our clients, each of our professionals is required to sign the NewtonX terms and conditions annually. These terms and conditions are binding, and through them the experts certify:

• Having reviewed any agreements, policies or laws to which they are subject to
• Having expressly verified that they are permitted to join NewtonX
• Proactively verifying whether sharing their expertise could violate any agreement, policy or law they may be subject to
• Declining or terminating any expertise sharing that moves into subject matters they cannot discuss
• Not providing confidential (including material non-public) information to clients
• Keeping all client information confidential (name, interests or any type of information)
• View the Professionals Terms and Conditions | Review the NewtonX Professionals Tutorial

Professional Compliance Training

We have designed a tutorial illustrating unequivocally the rules of professional knowledge sharing based on the latest legislation as well as NewtonX’s principles of confidentiality and discretion. This tutorial includes a series of exercises as well as questions and answers to ensure that our professionals adopt the right framework when sharing their knowledge. During these exercises they receive feedback along the way and thereby can easily adopt the most professional way of knowledge sharing.

The tutorial explains what constitutes “confidential information”, sensitizes professionals to any confidentiality obligations they may have towards our client as well as their current and previous employers, and emphasizes that our clients do not want – and will actually be harmed – if they receive confidential information.

We evolve in a dynamic industry and as such update our tutorial frequently. Professionals are required to take our tutorial at a minimum yearly, but may also be asked to take the tutorial upon our request if we deem necessary.

Employer Confidentiality

Transparency

Employees (including officers and directors) may not consult about their current employer – regardless of whether the employer is publicly held or privately owned. This prohibition extends to the parent and subsidiaries of an Advisor’s employer.

Furthermore, professionals are also required to follow strict guidelines regarding their previous employers. Even though they may share expertise related to the time of their previous employment, they are strictly forbidden to share any confidential information gained while working at any previous employer.

NewtonX offers an employer database registry, high levels of visibility, and custom compliance frameworks.

Visibility

We provide our clients with visibility into their activities at various levels:

• NewtonX users can track their activity, the different expert profiles already contacted as well as the potential profiles to be contacted
• Client oversight personnel have an aggregate view of the activity at the company level, and can trace which employees talked to which professionals at any point in time
• Client oversight personnel can also display specific metrics or implement specific triggers in order to adequately monitor the activity of their employees

Custom Compliance

We acknowledge that our clients have unique sets of needs. Consequently, we go beyond the standard client compliance program described above to also implement custom compliance processes for our clients, upon request.

• Notification of requests sent to oversight personnel for specific groups of professionals
• Pre-defined screening questions or attestations before entering into expertise sharing with specific groups of professionals
• Customized rules concerning former employees

Employer database registry

In order to prevent any conflict of interest with any organization, we have implemented a system by which organizations can register restrictions or guidelines concerning consulting activity by any of their professionals or employees. The output of this system is the NewtonX employer preference registry which we use to comprehensively enforce organizations’ policies prohibiting or limiting outside consulting to any of their employees. If you are an employer and want to inform us of any policies you have regarding outside consulting, please feel to do so by emailing us at compliance@newtonx.com.