Compliance Disclosure

2.1 Prohibition on MNPI

Experts are prohibited from disclosing Material Non-Public Information ("MNPI") during any engagement. MNPI includes, without limitation:

• Unannounced earnings, revenue, or financial results
• Pending mergers, acquisitions, divestitures, or strategic transactions
• Unannounced product launches, recalls, or discontinuations
• Pending regulatory approvals, denials, or enforcement actions
• Material litigation outcomes not yet publicly disclosed
• Changes in senior management not yet announced

2.2 Pre-Engagement Screening

Hudson screens experts against client exclusion lists and conducts conflict checks before every engagement. We refuse engagements where the topic, expert profile, and timing pattern indicate elevated MNPI risk.

2.3 Engagement Reminders

At the start of every engagement, both clients and experts are reminded — verbally and in writing — of the prohibition on MNPI exchange. Recordings (where applicable) capture these acknowledgments.

3.1 Expert-Level Conflicts

• Employment history (current and past employers within 24 months)
• Board memberships, advisory roles, and committee positions
• Direct or indirect financial interests (equity, options, debt holdings)
• Family relationships with employees of subject companies
• Consulting arrangements with competing entities

3.2 Client-Level Restrictions

Clients may provide exclusion lists identifying entities or individuals with whom they cannot interact (e.g., portfolio companies, regulatory targets, pending deal counterparties). Hudson enforces these restrictions automatically across all matching processes.

3.3 Cross-Engagement Conflicts

Hudson's systems track conflict patterns across engagements to identify situations where an expert's participation in one project may conflict with another. Where conflicts emerge, we suspend participation and notify affected parties.

4.1 Government Officials

Engagements with government officials, public sector employees, or state-owned enterprise representatives are subject to enhanced scrutiny. We verify the official's authority to participate, the legitimacy of the topic, and applicable disclosure requirements before scheduling.

4.2 Healthcare Professionals

For healthcare professionals subject to physician sunshine laws, Open Payments reporting (US), and equivalent transparency regimes, Hudson tracks and reports compensation as required by applicable law.

4.3 Prohibited Inducements

Compensation paid to experts must reflect fair market value for time and expertise. Hudson does not facilitate payments intended to influence business decisions, regulatory actions, or procurement outcomes.

5.1 KYC Procedures

We conduct Know Your Customer (KYC) checks on all clients and experts, including verification of legal entity status, beneficial ownership (where applicable), and screening against sanctions lists maintained by:

• U.S. Office of Foreign Assets Control (OFAC)
• European Union Consolidated Sanctions List
• UN Security Council Sanctions List
• Korean Ministry of Foreign Affairs sanctions list

5.2 Transaction Monitoring

We monitor payment patterns for indicators of unusual activity. Suspicious transactions are reported to relevant authorities as required by applicable law.

6.1 Lawyers & Legal Professionals

Engagements with attorneys are subject to bar association rules on confidentiality, attorney-client privilege, and conflict of interest. Experts must not disclose privileged communications or work product.

6.2 Accountants & Auditors

Engagements with accountants are subject to professional standards (e.g., AICPA, IFAC, KICPA) including confidentiality of audit information.

6.3 Financial Professionals

Engagements with licensed brokers, investment advisers, or banking professionals are subject to applicable regulatory frameworks (FINRA, SEC, FCA, FSC) and may require additional disclosures.

7.1 Off-Label Discussion Prohibition

Experts must not discuss off-label uses of pharmaceuticals or medical devices in a manner that could be construed as marketing, promotion, or solicitation.

7.2 PHI Protection

Personal Health Information protected under HIPAA, GDPR Article 9, and equivalent regulations must not be disclosed during engagements. De-identified or aggregated data may be discussed where appropriate.

7.3 Sunshine Act Reporting

For US-based physicians, dentists, podiatrists, and chiropractors, payments meeting reporting thresholds are reported to the Centers for Medicare & Medicaid Services (CMS) under the Open Payments program.

7.4 Clinical Trial Restrictions

Active clinical trial investigators may not discuss unblinded trial data, ongoing trial protocols, or interim results that have not been publicly disclosed.

9.1 Session Recording

Engagements may be recorded only with explicit, advance consent from all participants. Recording is disclosed at the start of each engagement and acknowledged on the audio/video record.

9.2 Audit Trail Components

For every engagement, Hudson maintains an audit trail that includes:

• Engagement scope, topic, and participating parties
• Pre-engagement screening questions and disclosures
• Conflict checks performed and results
• Compliance reminders issued to participants
• Session metadata (date, time, duration, channel)
• Any compliance flags raised during or after the engagement

9.3 Retention

Audit trails are retained for seven (7) years from engagement completion. Recordings, where created, are retained per the same schedule unless otherwise agreed in writing.

9.4 Regulatory Production

Hudson cooperates fully with lawful regulatory inquiries. Audit records may be produced in response to subpoenas, regulatory requests, or court orders, subject to applicable confidentiality protections.

10.1 Reporting Channels

• Email: hudson@hudsonexperts.com (subject line: "Compliance Report")
• Postal Mail: Compliance Officer, Hudson Research Partners, 24, Namdaemun-ro 9-gil, Jung-gu, Seoul, Korea
• Web Form: available on the Compliance section of our website

10.2 Anonymous Reporting

Reports may be submitted anonymously. Hudson maintains procedures to investigate anonymous reports while protecting the identity of reporters where possible.

10.3 Non-Retaliation

Hudson strictly prohibits retaliation against any individual who reports a compliance concern in good faith. Retaliation is itself a violation of our Code of Conduct and may result in termination of business relationships.

10.4 Investigation Process

All reports are reviewed by Hudson's Compliance Officer and, where appropriate, escalated to senior leadership or external counsel. Findings and remediation actions are documented in our compliance records.