General:

1. The main goal for the portfolio is to give high absolute return and excess return in comparison to the reference index.
2. The portfolio has a dedicated portfolio manager. The portfolio manager is responsible for the manual operation of the portfolio, the quality of the portfolio reports, and the results of the portfolio.

1. The portfolio is updated regularly with fixed intervals on a daily or weekly basis.
2. Portfolio updates should be published before trading starts, giving due time for investors to review the changes before the open. If possible, the update is also done before it is possible to view pretrade or preorders. The absolute minimum margin is 10 minutes, but normally the update is done at least 30 minutes before orders/prices can be seen. If the portfolio manager finds it impossible to update within this margin, the update is postponed till next day, and a short message on this is written in the portfolio report.
3. Once the portfolio is updated, the portfolio will not be changed till the next day. The only reason for updating it before the next regular update is to correct serious errors in the portfolio report.

1. The stocks in the portfolio is the result of a thorough selection process, based on Investtech's automated analyses.
2. The portfolio contains 5-10 companies. Normally 0-3 companies are changed each week or at each update.
3. No more than 33% of the companies should be within one sector. This is important to reduce the risk and variance in the portfolio results.
4. All stocks in the portfolio shall be liquid. As a general rule, the mean daily turnover should exceed 0.1 mill $, £ or €, or 1.0 mill kr. For small exchanges (OSE, HSE, DKS), this is not an absolute rule, but the liquidity shall at least exceed 0.01 mill € or 0.1 mill kr and be sharply rising.
5. All tickers in the portfolio should be tradable stocks. For example indexes shall not be selected. Funds shall not be selected if there is a higher transaction cost than for stocks. Derivatives shall not be selected.

1. Portfolio management requires high ethical standards by the portfolio manager. Ethical rules are stated and described in Investtech's standard employment agreement. The rules below covers the most important aspects, but high ethical standard does not restrict to this. The portfolio manager is specifically instructed to be aware of keeping high ethical standard when giving direct investment advises. If in doubt, the instruction is to be cautious.
2. To ensure that portfolio recommendations are based on objective analysis, specific reasons are needed when recommending a stock that the portfolio manager, or any other Investtech employee, already owns. Stocks owned by either Investtech, a person defined as an analyst, or members of their household, cannot be recommended. The portfolio manager, Investtech or an analyst are not allowed to sell stocks that are in the recommended portfolio before a minimum of two (2) days after the stock is taken out of the portfolio.
3. If the portfolio manager or any other Investtech employee owns shares in any of the companies included in the recommended portfolio company, this will be stated in the portfolio report.
4. Stocks where the portfolio manager knows possible price sensitive information, released after the close (message, article, price move at other exchange etc), shall not be taken in or out of the portfolio. Extra caution shall be applied when considering if the information is price sensitive or not.
5. All portfolio changes are logged with update times, prices etc. These logs will be reviewed by Investtech's internal compliance manager to ensure that the above rules are followed, so that our users can be sure that Investtech continues to improve its position as a highly respected, objective and informative advisor.