Asian Value Investor
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Ethics policy

Effective 5 October 2026. Last updated 5 October 2026.

Officers of Icarus Asia Limited and Asian Value Investor agree to adhere to Securities and Futures Commission, Hong Kong SAR's Guidelines on Disclosure of Inside Information, 2012. The guidelines are meant to assist listed corporations in complying with their obligations to disclose inside information under Part XIVA of the Securities and Futures Ordinance (SFO), including its subsidiary legislation. Though these guidelines are for listed firms in Hong Kong, officers of Icarus Asia and Asian Value Investor agree to adhere to the same.

If you feel these guidelines haven't been adhered to, reach out to us at contact@asianvalueinvestor.com or report any suspected violations to the SFC at https://www.sfc.hk/en/Lodge-a-complaint

1. Purpose and Scope

This Ethics Policy establishes standards of conduct for all personnel involved in creating content for Asian Value Investor, including staff analysts, writers, editors, freelance contributors, guest columnists, researchers, and translators (collectively "Contributors").

The policy is designed to maintain editorial independence, objectivity, and reader trust by preventing conflicts of interest and ensuring that all published research serves solely the interests of our readers.

2. Personal Investment Restrictions

2.1 Prohibition on Direct Positions

Contributors shall not, under any circumstances, take financial positions—long or short—in any stocks, securities, bonds, derivatives, options, or other financial instruments that they:

  • Analyze or write about in published work
  • Are actively researching for potential coverage
  • Have covered within the preceding 12 months

This prohibition includes but is not limited to:

  • Individual equity positions
  • Options and derivatives
  • Leveraged or inverse ETFs focused on specific sectors under coverage
  • Positions held by immediate family members residing in the same household
  • Discretionary accounts managed on the Contributor's behalf

2.2 Permitted Investments

Contributors may invest in:

  • Broad-based market index funds or ETFs (e.g., S&P 500, MSCI World Index) with no sector or regional focus relevant to their coverage area
  • U.S. government bonds, Treasury securities, and money market funds
  • Mutual funds and ETFs that are fully disclosed to the Editorial Compliance Officer
  • Real estate, commodities (physical holdings only), and cryptocurrency (subject to pre-approval)

2.3 Pre-Clearance Requirement

All Contributors must submit a complete list of their investment holdings, including those of immediate family members, to the Editorial Compliance Officer within 10 business days of commencing work for Asian Value Investor.

Any new investment not in the "permitted" category must receive written pre-clearance from the Editorial Compliance Officer before purchase.

3. Trading Blackout Periods

3.1 Pre-Publication Restriction

Contributors shall not purchase or sell any security within seven (7) calendar days before publishing research or commentary on that security or its sector.

3.2 Post-Publication Restriction

Contributors shall not purchase or sell any security within thirty (30) calendar days after publishing research or commentary on that security or its sector.

3.3 Exceptions

Blackout period restrictions do not apply to:

  • Automatic dividend reinvestment plans
  • Employer-sponsored retirement plans with automatic contributions
  • Rebalancing of pre-approved index funds and broad market ETFs

4. Gifts, Compensation, and Hospitality

4.1 Prohibited Gifts

Contributors may not accept:

  • Cash, gift cards, or any financial instruments from companies, investors, public relations firms, or third parties with an interest in coverage
  • Gifts valued over USD $50 from any single source within a 12-month period
  • Travel, accommodation, or entertainment paid for by entities that may benefit from favorable coverage (exceptions for sponsored press trips must be disclosed in published articles)

4.2 Permitted Benefits

Contributors may accept:

  • Promotional items of nominal value (e.g., branded pens, notepads, company reports)
  • Meals in the course of business meetings if the value does not exceed USD $100 per person
  • Access to earnings calls, investor presentations, and industry conferences open to media and investors

4.3 Outside Compensation

Contributors must not accept compensation—monetary or otherwise—from any company, investor, or related entity for producing favorable or unfavorable analysis.

Freelance or consulting work unrelated to Asian Value Investor content must be disclosed to the Editorial Compliance Officer.

5. Disclosure Requirements

5.1 Mandatory Author Disclosures

All published research, analysis, and opinion pieces must include a disclosure statement indicating:

  • The author has no financial interest in any securities mentioned
  • The author received no compensation from any company or third party for the content
  • If applicable: relationships, prior employment, or affiliations that could influence objectivity

5.2 Institutional Disclaimers

Every article will include a standard disclaimer:

"This article represents the personal views and analysis of the author(s). Asian Value Investor and its contributors do not hold positions in any securities mentioned unless otherwise disclosed. This is not investment advice. Readers should conduct their own due diligence."

6. Editorial Independence

6.1 Separation from Business Operations

The editorial team operates independently from the business and revenue operations of Icarus Asia Limited. Business development, advertising, and sponsorship teams shall have no influence over editorial content, research conclusions, or coverage decisions.

6.2 Prohibition on Pressure or Influence

No Contributor may:

  • Alter analysis, ratings, or recommendations based on commercial relationships
  • Suppress negative findings to maintain access to company management or investor relations
  • Coordinate publication timing with companies or investors to maximize market impact

6.3 Pre-Publication Review

Contributors may not share unpublished research, conclusions, or investment theses with companies under coverage, their representatives, or investors prior to public dissemination, except for fact-checking purposes under strict non-disclosure agreements.

7. Enforcement and Remediation

7.1 Reporting Violations

Contributors who become aware of potential ethics violations must report them immediately to the Editorial Compliance Officer at contact@asianvalueinvestor.com. Reports may be made anonymously.

7.2 Investigation Process

All reported violations will be investigated by the Editorial Compliance Officer in coordination with senior editorial leadership. Investigations will be conducted confidentially to the extent possible.

7.3 Consequences

Violations of this Ethics Policy may result in:

  • First offense: Written warning and mandatory ethics training
  • Second offense: Suspension from publishing for a period determined by senior editorial leadership
  • Third offense or egregious violations: Termination of relationship with Asian Value Investor and public disclosure of the violation

7.4 Corrections and Retractions

If an ethics violation is found to have influenced published content, Asian Value Investor will promptly issue a correction or retraction, including an explanation of the circumstances. Affected readers will be notified via newsletter and website updates.

8. Annual Certification

All Contributors must certify in writing on an annual basis that they:

  • Have read and understood this Ethics Policy
  • Have disclosed all financial interests and potential conflicts of interest
  • Have complied with all applicable restrictions and requirements
  • Agree to notify the Editorial Compliance Officer immediately of any changes in circumstances that may create a conflict

9. Contact Information

For questions about this Ethics Policy or to report concerns, please contact:

Editorial Compliance Officer

Asian Value Investor

Email: contact@asianvalueinvestor.com

General Inquiries: contact@asianvalueinvestor.com

10. Policy Updates

Asian Value Investor reserves the right to amend this Ethics Policy at any time. Contributors will be notified of material changes and must acknowledge their agreement to the updated policy within 14 days of notification.

Continued contribution to Asian Value Investor constitutes acceptance of the Ethics Policy as amended.

11. Disclosure of Relationships

AVI's founder and executive editor, Kenan Machado, is also Executive Director at Icarus Asia, a risk and advisory firm, and AVI is operated by Icarus Asia Limited. AVI republishes research that Icarus Asia first published, under the byline Icarus Asia Research. We say on the page when a piece concerns Icarus Asia, its clients or its affiliates.

12. Use of AI

The rules on AI-assisted work, including disclosure, human review and confidentiality, are in section 9 of the Editorial Policy. They form part of this Ethics Policy.