Peakwood Capital – Disclosure Policy

Last Updated: February 2025

At Peakwood Capital, when it comes to matters of money, we believe in transparency and accountability. We are dedicated to delivering responsible investing ideas and sound financial education to our subscribers. Because we talk about stocks, markets, and investment strategies, we think it’s important that you understand where we are coming from and how we handle potential conflicts of interest.

With this in mind, we have developed a firm-wide disclosure policy to guide our business, our research processes, and our communications. We invite you to read this Disclosure Policy carefully, as it is designed to help you interpret our commentary and recommendations within the proper context.

1. Investors Communicating With Investors

Peakwood Capital is run by people who actively invest in the markets. We believe that the best way to understand investing is to participate in it. Many traditional financial publications prohibit their writers from owning stocks. We take a different view.

We believe:

• Long-term ownership of quality businesses can be an effective path to wealth creation.
• Serious investors learn best by doing – researching companies, making decisions, and living with the outcomes over time.
• People who invest their own capital in the markets often develop a deeper understanding of risk, volatility, and real-world trade-offs.

For these reasons, we allow and encourage our team members to invest personally in stocks and other securities. We do not view our editors or analysts as neutral journalists, but as financial educators and communicators who are invested in the same types of markets they write about.

That said, personal investing by our team can create potential conflicts of interest. This Disclosure Policy explains how we identify, manage, and communicate those potential conflicts.

2. Our Content and Recommendations

Peakwood Capital publishes research and commentary in different formats, including:

• email newsletters (including free and paid editions);
• special research reports and one-time publications;
• online member-portal content; and
• educational articles, guides, and market commentary.

In some of these Services, we may:

• highlight individual stocks, ETFs, funds, or other securities;
• present “watchlists” or model ideas; and
• discuss investing themes, strategies, or sectors at length.

We may also publish model portfolios or illustrative allocations. These are offered solely for educational and informational purposes and are not personalized investment advice. We will disclose where we or members of our team have positions or beneficial interests in securities that we discuss, as described below.

3. Core Disclosure Principles

To promote transparency, we follow these core principles:

• Personal Ownership Disclosure: If a contributor (such as an analyst, editor, or writer) has a personal position or beneficial interest in a stock or other security that is mentioned in our content, that fact will be disclosed in or alongside the applicable content, subject to reasonable space and format constraints.
• Firm Recommendation or Position Disclosure: If Peakwood Capital, or an affiliated entity under our control, currently recommends or holds a position in a security that is discussed, we will disclose that fact in or alongside the content.
• Timeliness of Disclosure: We will maintain relevant disclosures for as long as we continue to actively recommend or discuss the security in question, or while a position is held by the firm or covered team member, subject to our internal procedures.

Our goal is to give you enough information to understand when our interests may be aligned with, or differ from, your own investment decisions.

4. Employee and Contractor Position Reporting

To support the disclosure process, Peakwood Capital may require employees, key contractors, and certain contributors to report their personal investment holdings on a periodic basis. This can include:

• individual stocks and ETFs;
• pooled investment vehicles (such as mutual funds or index funds); and
• other securities that are relevant to the topics we cover.

In general, we treat individual mutual fund holdings as diversified vehicles for which underlying positions are not individually disclosed. Where appropriate, however, we may disclose that an individual invests through certain funds or vehicles, especially when discussing those funds directly.

We use position information for internal compliance purposes and to support appropriate disclosure in our educational content. We do not publicly publish complete, detailed holdings lists for each employee.

5. Trading Restrictions and Guidelines

In addition to our disclosure practices, we impose internal trading guidelines designed to reduce the risk of conflicts between personal trading and our published research. These guidelines may include some or all of the following restrictions:

• Minimum Holding Period: Covered employees and contributors are generally expected to hold any stock they purchase for a minimum period (for example, at least 10 calendar days), and to avoid short-term trading that looks like day-trading or speculative flipping.
• Trading Blackout Windows: Covered individuals may be restricted from trading a security within a defined “blackout” window surrounding publication of content about that security (for example, for a period of days before and after an article or recommendation is published).
• Pre-Clearance Requirements: Certain employees may be required to obtain internal approval before entering buy or sell orders in securities that are covered by our research.
• Post-Trade Reporting: Covered individuals are expected to promptly report securities trades to our internal compliance function, so that we can maintain appropriate oversight.

These internal guidelines are intended to promote fairness and transparency. They are subject to refinement over time as our business and regulatory environment evolve.

6. Investors in Peakwood Capital

Peakwood Capital may have investors and owners, including its founders, team members, and outside investors. In certain cases, our investors, executives, or employees may also invest in securities or industries that we cover in our research and newsletters.

We design our research and editorial processes to be independent from the personal investment decisions of our owners and investors. Our goal is to align our long-term incentives with those of our subscribers by emphasizing quality research, education, and a long-term perspective.

7. Business and Technology Partners

Peakwood Capital maintains business relationships with a variety of partners, which may include:

• technology and hosting providers;
• payment and billing processors;
• marketing, analytics, and advertising partners;
• data and research providers; and
• professional advisors and other vendors.

Some of these partners may be publicly traded companies operating in sectors that we discuss in our research. There may be occasions when our newsletters or reports mention companies with whom we have a business relationship. These occurrences are incidental and not intended as endorsements based solely on that relationship. Our editorial team operates independently of our business and vendor relationship decisions.

Because partner lists and vendor relationships can change over time, we do not publish a static list of all partner companies. Where we believe a specific relationship is material to the discussion of a particular company or product, we will seek to disclose that relationship in or alongside our content.

8. Advertising, Affiliate, and Referral Relationships

Peakwood Capital may receive compensation from third parties in connection with:

• displaying advertisements on our Sites or in our emails;
• featuring sponsored content or promotions; or
• including affiliate links or referral links to third-party products and services.

For example, we may receive compensation when our readers click on certain links, open accounts with partner firms, or purchase products or services that we mention. We may highlight products or services that we believe are relevant or potentially valuable for our audience, but such references do not guarantee that a product is the best or only available option.

We seek to comply with applicable U.S. Federal Trade Commission (FTC) guidelines regarding endorsements and advertising. Where appropriate, we will identify content or links as sponsored or affiliated.

9. Separation of Editorial and Business Functions

We strive to maintain a separation between our editorial research and our business relationships. This means:

• Our research and educational commentary are developed with a focus on long-term investing and educational value for our subscribers.
• Advertising sales, affiliate arrangements, sponsorship deals, and other commercial agreements are handled by our business team and do not dictate our editorial views.
• While we may cover companies that are also business partners, we aim to disclose any relationship that could reasonably be viewed as a conflict of interest.

10. How to Interpret Our Commentary and Recommendations

Our newsletters and research materials are meant to provide ideas, frameworks, and education—not personalized investment advice. Even with strong internal policies, disclosures, and trading guidelines, it is essential that:

• you treat every idea as a starting point for your own research;
• you evaluate whether any given investment is appropriate for your financial situation, objectives, and risk tolerance; and
• you recognize that all investments carry risk, including the risk of total loss.

Nothing in our content should be interpreted as a guarantee of results, or as a promise that a particular security or strategy is suitable for any specific individual.

11. Updates to This Disclosure Policy

We may update this Disclosure Policy from time to time to reflect changes in our business practices, regulatory environment, or internal compliance procedures. When we do, we will revise the “Last Updated” date at the top of this page. We encourage you to review this Policy periodically so that you remain informed about how we manage potential conflicts of interest and how we communicate about our investing activities.

12. Questions and Contact Information

If you have questions about this Disclosure Policy or how it applies to our content and Services, please contact us at:

Peakwood Capital
Email: support@peakwoodcapital.com

This Disclosure Policy is intended to provide transparency about our investing and business practices. It does not replace your responsibility to conduct your own research and make your own financial decisions. You should consult with qualified financial, legal, and tax professionals before making any investment decisions.