Disclosures
Research Conflict Management Policy
This represents a summary of certain polices adopted by B.
Riley Securities, Inc. concerning conflicts in connection with the production
and/or dissemination of Investment Research.
Content and Integrity of Research
Our research is produced for the benefit of our clients, and
our policies were created to ensure that research is independent, objective,
fair, and clear.
Integrity
Research analysts are required to observe high ethical
standards to ensure the integrity of research opinion. Research opinion is
subject to content standards, including requirements that analyst have a
reasonable basis for any opinion, and that opinions be balanced and accurately
reflect the analyst viewpoint.
Our procedures require research analysts to immediately
report any potential conflict to Research management and Compliance, who will
review the potential conflict to ensure the independence and objectivity of
analyst opinion is not compromised.
Research analysts are required to certify the opinion
presented in reports and public appearances accurately reflect their views and
that no part of the analyst's remuneration was, is, or will be directly or
indirectly related to specific recommendations or views expressed in such
reports or appearances.
Identification of Conflicts
Our policies address the requirement to identify and manage
certain conflicts that may compromise the independence of our research
analysts, including potential conflicts involving Research and Investment
Banking, Research and Sales & Trading, and Research and other departments.
All our employees are provided copies of our policies and receive
training on them, including training addressing the obligation of a research
analyst to inform Research senior management and Compliance of any such
potential conflict so that it can be reviewed and addressed before research is
published.
Our policies include Information Barriers and other controls
to restrict the sharing of information between Research and other departments.
Contacts between research analysts and investment Bankers
generally require pre-approval by their supervisors and in certain
circumstances are monitored or chaperoned by Compliance or Legal.
Our policies also require restricting and/or monitoring of Research
during the period surrounding investment banking transactions and other
potential restricted periods.
Our policies require Research supervisory approval of all
research prior to its publication, with escalation to Compliance as
appropriate, as well as a preapproval process for all research analyst public
appearances.
Supervision and
Remuneration of Research Analysts
The reporting line for all Research personnel, including senior
management, is independent from Investment Banking.
Research has sole authority to determine which issuers will
receive coverage and the timing and content of coverage, including termination
of coverage.
Research analyst remuneration is determined by Research senior
management and reviewed by a Research Analyst Compensation Committee, which
includes members from outside the Research Department but does not include
anyone from Investment Banking. Research analyst remuneration is based on a
number of factors, including the quality, scope, and depth of analyst coverage.
Analysts are eligible to receive bonus compensation that is based on overall
operating revenues, including revenues generated by Investment Banking and
Sales & Trading. Investment Banking has no input to analyst compensation or
the Research Department's budget.
Research Analyst Activities
Research analysts are not permitted to engage in activities
that would compromise the objectivity or integrity of their research.
Considerations include:
Analysts are not permitted to engage in 'pitches' for new
business or 'road shows' for new issues of financial instruments, or otherwise
engage in marketing of investment banking transactions.
Analysts are not permitted to engage in joint appearances
with an issuer or Investment Banking to our Sales & Trading personnel or to
clients in connection with an investment banking transaction.
Analysts may engage in vetting or due diligence and certain
other activities as approved in connection with potential or actual Investment
Banking clients or transactions.
While research analysts are not permitted to engage in
solicitations or marketing of specific investment banking transactions to
clients, they may serve an educational role for both Sales & Trading and
clients in connection with an investment banking transaction.
Research analyst involvement in any activities in connection
with a potential or actual investment banking transaction, including vetting or
diligence, must be approved by Research senior management and Compliance.
Inducements and
Inappropriate Influences
Research analysts are prohibited from receiving any
inducement from an issuer or otherwise in connection with research opinion.
Research analysts are not permitted to disseminate proposed
initiations of coverage, research opinion, changes in research opinion, and
terminations of research opinion outside of the Research Department until
published, with certain exceptions specifically approved by senior management
and Compliance.
Research analysts are prohibited from directly or indirectly
offering favorable research, a specific rating, a specific price target, or
threatening to change the timing or content of research or threatening to drop
coverage in connection with or in exchange for investment banking and/or sales
& trading business.
Investment Banking personnel are prohibited from directing a
research analyst to engage in marketing efforts.
Research analysts are prohibited from agreeing to be
restricted by an issuer concerning the use of information received from an
issuer and must notify Research senior management and Compliance of any such
approach.
Research analysts are required to immediately report to
Research senior management and Compliance any retaliatory actions by employees
or issuers.
All employees are prohibited from engaging in retaliatory
action against a research analyst related to analyst opinion.
Research analysts are required to certify the opinions
expressed in reports and appearances represent their personal view and that no
part of their compensation was, is, or will be directly related to the specific
recommendation or viewpoint expressed by the analyst in the report or
appearance.
Research analysts are prohibited from engaging in any
conduct that would result in them being unable to provide the aforementioned
certification.
The Research Department is physically separated from all
other offices, including Investment Banking, Sales & Trading, and other
departments.
Method and Timing of
Publication
Information concerning the timing and content of unpublished
Research opinion is limited to Research and Compliance, with certain exceptions
specifically approved by Research senior management and Compliance.
Research is distributed to clients and employees
simultaneously through B. Riley Securities, Inc.'s usual distribution channels.
Prior to its distribution, research report content may not be communicated to
anyone except as specifically approved by senior management and Compliance.
When we are involved in particular investment banking or capital markets transactions, we may restrict the distribution of research opinion. Similarly, if research analysts are in possession of material non-public information concerning the issuer, they are required to notify Compliance and will be restricted from publishing or making appearances concerning that issuer. We may also restrict research for other reasons, including required regulatory quiet periods and other business or legal reasons.
Personal Account Trading
Research analysts are subject to personal trading procedures
that generally prohibit ownership of issuers they cover, as well as issuers in
the same industry, and analysts are generally prohibited from trading in the
securities of other issuers about which they possess knowledge of any pending
unpublished research opinion. Analysts
are required to make written representations concerning these conditions and
obtain pre-approval for all transactions prior to trading.
Research analysts' outside business activities must be
pre-approved by Research senior management and Compliance. Analysts are
prohibited from engaging in outside business activities with issuers they cover
and other outside business activities that would compromise their independence
and objectivity. Analysts are prohibited from serving as officers or directors
of public companies.
Disclosure of Interests
Our research reports provide disclosures as required by
applicable regulations and by our policies, including:
- a description of our rating system.
-
the distribution of our ratings.
When applicable, except where such disclosure would reveal
material non-public information:
- the research analyst owns shares of the subject issuer.
-
we or any of our affiliates own more than 1% of the issuer's
securities.
-
we or any of our affiliates served as a manager or
co-manager of an offering of the issuers securities within the past 12 months.
-
we or any of our affiliates received compensation for
investment banking services within the past 12 months from this issuer.
-
we or any of our affiliates expect to receive or intend to
seek compensation for investment banking transactions from the issuer within
the next three months.
- we or any of our affiliates have received compensation from the issuer for non-investment banking securities services within the past 12 months.
- we or any of our affiliates, currently or within the past 12 months, engaged in lending activity or similar services with the issuer for compensation.
- we or any of our affiliates, has acted as a placement agent on a private offering of the issuer's securities.
-
we are a market maker or liquidity provider in the issuer's
securities.
-
an employee serves as an officer or director of the issuer.
-
we and/or the research analyst are subject to any other
material conflict of interest of which we are aware at the time of publication.
We may not be required to provide and may elect not to
provide, certain disclosures concerning a business relationship with an issuer,
when such disclosure would reveal material non-public information regarding
specific banking transactions with the subject company.
We may include other disclosures as we consider appropriate.
Privacy Policies
Last Updated: September 11, 2020
Introduction: What This Privacy Policy Covers
GlassRatner Advisory & Capital Group, LLC, B. Riley Advisory & Valuation Services, LLC, Great American Group Intellectual Property, LLC, and Great American Group Machinery & Equipment, LLC, collectively dba B. Riley Advisory Services ("BRAS", "we" or "our") are committed to protecting your privacy. This privacy policy ("Policy") applies to your interactions with BRAS online and offline, including this website (the "Site") and BRAS services (the "Services"). The purpose of this Policy is to disclose BRAS practices related to information we collect from you and have about you. Please read this Policy carefully.
1. Collection of Your Information
2. Use, Sharing & Disclosure of Your Information
3. California Privacy Rights
4. Minors' Use of the Services
5. Changes to the Privacy Policy
6. International Users
7. Legal Basis for Processing Personal Information
This Policy applies to our Site and Services only. When you
visit websites to which we link, you will be interacting with another party
that operates under its own privacy and security policies. Personal information
you give to another party will be subject to that party's own terms,
conditions, and policies - not this Policy. You should review the other party's
privacy policy and terms of service before providing your information or using
their services. We encourage you to review the privacy policies of any other
website or application from which you request products or services.
We and our service providers may collect information about you when
you ask us to contact you, such as:
- your name;
- your address;
- your telephone
number;
- your company
affiliation, job title, and related information;
- the nature of your
request; and/or
- your email address
In addition, if you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses.
We and our service providers may also collect information that
you provide to us when you apply for a job, such as:
- your work history;
- your resume; and/or
- your academic background
Please see Section II of this Policy to see how we use, share and disclose information you have provided to us.
B. Information we collect
through your interaction with our Site:
We and our service providers may automatically collect
information from your access device and browser, including:
- what type of browser you use;
- processor type;
- operating system; and
- IP address
As you browse and interact with our
Site, we and our service providers may automatically collect information
related to your use of the Site, including:
- how often you visit the Site; and
- how you navigate and conduct searches on our Site
Please see Section II of this Policy to see how we may use, share and disclose information we collect through your interaction with our Site or Services.
C. Information we receive from other parties:
We may collect information about you from other sources, including publicly available sources and our Affiliates or our partners, service providers or others, in order to update or supplement information we have collected directly from you. For example, we may use Google Analytics to measure and report statistics about your device, interests, location and interactions on the Site. An "Affiliate" is a company that controls, is controlled by or is under common control with BRAS.
D. Information collected
through technological methods:
In addition, we may use, and may allow our service providers to use, technological methods such as cookies or web beacons to collect information about you. Cookies are small pieces of data that may be stored on your computer, mobile device, or other similar device and are used to make the Site easier to use and to analyze use of the site.
E. Retention of Information:
BRAS retains the information we collect for as long as necessary
to (i) provide our services to you, (ii) comply with legal obligations, (iii)
resolve disputes, and (iv) enforce our agreements.
Please see Sections II and III of this Policy to see how we use, share and disclose information collected through technological methods.
2. Use, Sharing & Disclosure of Your Information
A. How we use your information:
We use the information we collect in a variety of ways,
including:
- to operate and improve the Site;
- to understand your use of the Site;
- to communicate with you;
- to notify you about important changes to our website, new services and special opportunities we think you will find valuable; and
- to develop research reporting for us, our Affiliates and third party market research partners.
B. How we share your information:
We may share your information, including in some cases information that specifically identifies, relates to, or could be associated with you, directly or indirectly, ("personal information") such as your name, your email address, your physical address or telephone number, with Affiliates and trusted partners and service providers in ways including the following:
- to help operate the Site and Services;
- to facilitate fulfillment of a transaction or request; and
- to provide research reporting for us, our Affiliates and our service providers.
Examples of service providers may
include providers who compile and analyze data collected by us (e.g., Google
Analytics), service providers who supplement or match information we have
collected with information from other parties, market research companies,
website hosts, and email support vendors.
In addition, we may share information in the following circumstances:
- without notice, to law enforcement or government agencies in response to subpoenas, court orders, or other legal process (including civil and criminal) or otherwise as required by law;
- in connection with the actual or potential sale of our business.
Please see Section I of this Policy to see the types of information we collect.
3. California Privacy Rights
If you reside in California, you can make the following requests with respect to your personal information:
- Access - You can
request that we disclose to you the categories of personal information
collected about you, the categories of sources from which the personal
information is collected, the categories of personal information sold (if
applicable) or disclosed, the business or commercial purpose for collecting and
selling (if applicable) the personal information, the categories of third
parties with whom we share the personal information, and/or the specific pieces
of personal information collected about you over the past 12 months.
- Deletion - You can
request that we delete your personal information that we maintain about you,
subject to certain exceptions.
- Opt-out - For
purposes of this privacy policy, "sell" means the
sale, rental, release, disclosure, dissemination, availability, transfer, or
other oral, written, or electronic communication of your personal information
to an outside party for monetary or other valuable consideration. Based on our
understanding of California law, we do not sell your personal information, so
we do not offer the opt-out right.
BRAS will not discriminate against
you because you made any of these requests. California residents can make these
requests online by emailing us at emailing us at [email protected] or by calling
us toll-free at 310-966-1444.
We may deny certain requests, or fulfill a request only in part,
based on our legal rights and obligations. For example, we may retain personal
information as permitted by law, such as for tax or other record keeping purposes,
to maintain an active account, and to process transactions and facilitate
customer requests.
We will take reasonable steps to verify your identity prior to
responding to your requests. The verification steps will vary depending on the
sensitivity of the personal information and whether you have an account with
us.
California residents may designate an authorized agent to make a
request on their behalf. When submitting the request, please ensure the
authorized agent is identified as an authorized agent.
For purposes of these requests, please note the following regarding how we collect and use your personal information as described in this Policy:
- We collect and use the following categories of personal information as set forth in the California Consumer Privacy Act of 2018: identifiers; personal information categories listed in Cal. Civ. Code § 1798.80(e); commercial information; internet or other electronic network activity information; and professional or employment-related information.
- We collect these categories of personal information from you, your devices, publicly available sources, our Affiliates, our service providers, and our business partners.
- We use these categories of personal information for our business and commercial purposes described in Section II of this Policy.
- We disclose these categories of personal information to our Affiliates, service providers, business and advertising partners, law enforcement, and potential acquirers of our business, as described in Section II of this Policy.
4. Minors' Use of the Services
BRAS offers a general audience Site. This Site is not intended for children under the age of 16.
5. Changes to the Privacy
Policy
By using the Site or Services, you signify your acceptance to
this Policy. If you do not agree to this Policy, please do not use any of the
Site or Services. We reserve the right to make changes in this Policy at any
time. Please check the Policy each time you use our Site or Services to ensure
you are aware of any changes in our privacy practices. Your continued use of
our Site or Services will signify your acceptance of the changes to this
Policy. Notification of any material changes to this Policy will be posted on
the BRAS home page.
If you have any questions about this Policy please contact us
at:
B. Riley Advisory Services
11100 Santa Monica Blvd.
Suite 800
Los Angeles, CA 90025
6. International Users
The information we collect from users is processed and maintained in the United States, where privacy laws may not be as protective as in your home country. If you are using our Site or Services from outside of the United States, by providing information to us you are consenting to the transfer of the information to the United States for processing in a manner consistent with this Policy. If you are accessing this website from a European Union member state, you have the right to object to the collection and processing of your personal data as set forth in this Privacy Policy, and if you wish to do so please notify us at the address above. Please bear in mind that if you object this may affect our ability to provide you with the Services.
7. Legal Basis for Processing
Personal Information
If you are a visitor from the European Union member state, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. We will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you. If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), such legitimate interests include: (i) improving our Site and Services; (ii) responding to inquiries from you; (iii) measuring and improving the effectiveness of our marketing activities; and (iv) transmitting data internally within our company for administrative purposes.
Review B. Riley Wealth Management's Privacy Notice to Clients.