1. Information regarding securities and issuers must be complete, truthful, up-to-date, clear, objective and lawful, including that which is inserted in the research report of a given issuer or relating to shares issued by the same;

2. The information disclosed in research reports and recommendations for investment based on such reports are likely to influence the decisions of the investing public;

3. All persons intervening in the securities market, in particular issuers and financial intermediaries, should adopt a policy of fairness and transparency when dealing with personal investors, and their activities should be governed by high standards of diligence and loyalty, geared towards avoiding or greatly reducing the risk of conflicts of interest arising;

4. Issuers are obliged to immediately inform personal investors of any event occurring during the course of their issuing duties which has not been made public and which is likely to have an impact on share prices;

5. The collaboration of issuers in ensuring the quality of information divulged in research reports must not involve the disclosure confidential information;

6. From the moment when an offering is made public, any information pertaining to the issuer or to the offering, including that which is divulged in a research report, must clarify the link between the author of the report and the issuer or offeror, and any interest which the author might have in the offering;

7. The present Recommendations must be observed by authors of research reports, containing recommendations for investors, which are not financial intermediaries but are nevertheless subject to supervision by the CMVM;

8. All persons carrying out activities related to the trading of securities, be it as a key figure or an accessory, are subject to supervision by the CMVM;

9. The CMVM aims, in its supervisory role, to contribute to the improved quality of information disclosed, including that which is divulged in research reports, thus protecting the rights of investors;

10. For the effects of the present Recommendations, research is taken to mean activities involving the searching for and analysis of information pertaining to a given issuer or given securities, with a view to the drawing up of a report which expresses an opinion on the issuer or securities being analysed; or a generic recommendation on investment or disinvestments in securities:

the CMVM, under the terms of Article 370 of the Portuguese Securities Code, has approved the following recommendations:

I. IIt is hereby recommended that securities issuers, in the information they disclose to financial analysts producing research reports:

1. Contribute to the correct and impartial assessment by financial analysts of companies and shares issued by them, explaining and clarifying their strategy and business objectives;

2. Clearly differentiate between information pertaining to the current financial and economic state of affairs of the company and information relating to objectives, forecasts and perspectives related to the activities, business or results of the company;

3. Clearly and objectively indicate their plans and the criteria used in formulating their objectives, forecasts or perspectives;

4. Update all information presented to financial analysts by revising it periodically;

5. Abstain from influencing the financial analyst in any way, at present or in the future, with regard to the contents of the research report being drawn up and the recommendations being made by the financial analyst.

1. Ensure that all those responsible for the production of the research report in question are capable of acting with the correct degree of independence, correctness and impartiality, particularly as regards business sectors which have direct links to the company being assessed or which trade securities on behalf of third parties or for themselves;

2. Keep payments made to the financial analyst separate from receipts generated by transactions carried out by the financial intermediary, either on behalf of a third party or for him/herself, on securities issued by the company being assessed;

3. Keep an updated register of transactions carried out by financial analysts;

4. Abstain from trading securities issued by the company being assessed as the date of completion and publication of the research report nears;

5. Ensure that the research report being drawn up permits interested parties to:

5.1 Identify and differentiate between perspectives and forecasts expressed by the company being analysed and those expressed by the financial analyst;

5.2 Identify the pretexts underlying the analysis and the methods of assessment used;

5.3 Identify the date of commencement and conclusion of disclosure of the research report in question, and also all those responsible for drawing up the report;

5.4 Identify, in general terms, the existence of relations, and eventual financial gains arising from these, between the financial intermediary or a company in which the intermediary has a controlling interest or with which it has a group relationship, and the company being analysed;

5.5 Be informed of positions held and duties carried out by the financial intermediary or by an individual charged with producing the research report, in the administration or departments of the company being assessed;

6 Include, in the research report in question, warnings directed at non-professional investors with respect to the risks posed by recommendations made in the report, and regarding the fact that the said recommendations, being dependent on the evolution of the company and subsequent alterations to the forecasts, projections and methods of analysis used, are therefore subject to change;

7 When publicly disclosing recommendations to invest in securities of a given issuer:

7.1 Make the research report that forms the basis for any such recommendations regarding investment in the securities of a given issuer available for consultation, or at least indicate the location or electronic address where the report can be consulted.

7.2 State whether or not the report was initially drawn up for a specific person, regardless of the identification of the same.

 

1. Diversify their sources of information so as to enable them to make more informed investment decisions;

2. Use credible sources of information;

3. Conduct an analysis of all past recommendations made by the financial intermediary and the financial analyst, particularly with regard to increased profitability resulting from such recommendations;

4. Carefully analyse the entire research report in question, in particular with respect to projections, forecasts and perspectives expressed by the financial analyst, and paying attention to the dates on which work on the report commenced and concluded, as well as the date on which it was divulged and the conclusions drawn therein;

5. Pay attention to warnings issued in research reports to non-professional investors regarding the risks involved and possible alterations to projections, forecasts and the methodology used in drawing up such a list of recommendations;

6. Consider the possibility that the recommendations expressed in the research report may not be the most appropriate to a given investor's risk profile, to the diversification of his/her securities portfolio, or to his/her experience or availability to manage investments in securities;

7. Consider the possibility that the economic value of the recommendations made in the research report may have dissipated in the period of time between the dates on which the said recommendations were formulated and made public;

8. Pay special attention to research reports released close to the dates of events bearing particular significance for the company being analysed or the securities markets in general (e.g. decisions related to the launching of public offerings or capital increases), given the increased risk of conflicts of interest arising from such events.