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Our Best Practices for survey research sets forth the rules of ethical conduct. It is organized into sections describing our responsibilities to Financial Advisor Respondents and Clients and in reporting study results.

FinancialAdvisorsnet.com is a leading sales & marketing data collection provider for the financial services industry. The Advisor Panel and recruitment portal are managed by DGL Consultants and powered by Qualtrics. DGL has over 30 years invested in building professional relationships and the most geographically diverse financial advisor panel in the industry. Qualtrics, a leader in enterprise feedback management and survey software, provides the platform for designing, distributing and evaluating survey results.

FinancialAdvisorsnet offers online access to financial advisors in all retail distribution channels. Our one-of-a-kind Advisor Panel and survey focus enables us to quickly and cost-effectively capture the high quality answers you need to make decisions you can trust.

When partnering with FinancialAdvisorsnet, you are not only accessing a universe of information from one fast, reliable source but also our great asset, the experience and dedication of our team.

We have professional and legal responsibilites to our Respondents. Underlying these specific responsibilities are four fundamental ethical principals. Respondents should be:
 

1. Willing participants in survey research;
2. Appropriately informed about survey's intention and how their personal information and survey responses will be used and protected;
3. Sufficiently satisfied with their survey experience;
4. Willing to participate again in survey research.

A. Confidentiality

1. Since Respondents who participate are the lifeblood of our survey research, it is essential that we be responsible for protecting from disclosure to third parties — including Clients and Members of the Public — the identity of individual panelists as well as panelist identifiable information.
2. The principal of Respondent confidentiality includes the following specific safeguards:
1. Our staff will not use or discuss Respondent identifiable data for information for other than legitimate research purposes.
2. Before permitting Clients to have access to completed questionnaires for validation, Respondent's name and and other identifying information (e.g. email address) will be deleted.
3. The use of survey results in a legal proceeding does not relieve FinancialAdvisorsnet of its ethical obligation to maintain in confidence all Respondent identifiable information.

B. Privacy and the Avoidance of Harassment

1. FinancialAdvisorsnet has a responsibility to strike a proper balance between the needs for research in the financial services industry and the privacy of Financial Advisors who become panelists.
1. Panelists will be protected from any form of personal harassment.
2. Cooperation is voluntary.
2. This principal of privacy includes the following specific applications:
1. FinancialAdvisorsnet will make every reasonable effort to ensure that the Panelist understands the purpose of the contact.
2. Deceptive practices and misrepresentations, such as using research as a guise for sales or solicitation purposes, are expressly prohibited.
3. The unique characteristics of Internet research require specific notice that the principal of Panelist's privacy applies to this data collection methodology. FinancialAdvisorsnet will not use unsolicited emails to recruit survey Respondents or engage in surreptitious data collection methods.
1. Email Solicitation
1. Individuals contacted for research by email have a reasonable expectation that they will receive email contact for research;
2. A substantive pre-existing relationship exists between the Panelist contacted and FinancialAdvisorsnet or the Client supplying email addresses;
3. Survey email invitees have a reasonable expectation based on the pre-existing relationship where survey email invitees have specifically opted-in for Internet research with FinancialAdvisorsnet, or in the case of Client-supplied lists that they may be contacted for research and invitees have not opted-out of email communications;
4. Survey email invitations will clearly communicate the FinancialAdvisorsnet name and clearly offer the choice to be removed from future email contact.
5. FinancialAdvisorsnet will not use false or misleading return email addresses or any other false or misleading information when recruiting panelists. We must comply with all federal regulations that govern survey research activities. In addition, FinancialAdvisorsnet will use its best efforts to comply with other federal regulations that govern unsolicited email contacts, even though they do not apply to survey research.
6. When receiving email lists from Clients, FinancialAdvisorsnet will have the Client verify that individuals listed have a reasonable expectation that they will receive email contact.
7. The practice of "blind studies" (where the sponsor of the study is not cited in the email solicitation) is permitted if disclosure is offered to the panelists during or after completing the survey.
2. Active Agent Technology
1. Defined as any software or hardware device that captures the behavioral data about data subjects in a background mode, typically running concurrently with other activities. FinancialAdvisorsnet does not use any forms of this technology including "spyware".
2. A cookie (defined as a small amount of data that is sent to the computer's browser from a web server and stored on the computer's hard drive) is not an active agent. Although the use of cookies is permitted, FinancialAdvisorsnet does not subscribe to their use.
3. Following is a list of unacceptable practices that FinancialAdvisorsnet strictly forbids and does not engage in:
1. Downloading software without obtaining the data subject's informed consent.
2. Downloading software without providing full notice and disclosure about the types of information that will be collected about the data subject, and how this information will be used. The notice needs to be conspicuous and clearly written.
3. Collecting information that identifies the data subject without obtaining affirmed consent.
4. Using keystroke loggers without obtaining the data subject's affirmed consent.
3. The Financial Advisor Panel/Sample Source Considerations
1. Disclose to panel members that they are part of a panel.
2. Obtain panelist's permission to collect and store information about the panelist.
3. Collect and maintain records of panel activity.
4. Upon Client request, FinancialAdvisorsnet will disclose:
1. Panel composition information (including panel size, populations covered, and the definition of an active panelist).
2. Panel recruitment practice information.
3. Panel member activity.
4. Panel incentives.
5. Panel validation practices.
6. Panel quality practices.
7. Aggregate panel and study sample information (this information could include response rate information, panelist participation in other research by type and timeframe).
8. Study related information such as email invitation(s), screener wording, dates of email invitations and reminders.
5. Stewardship of the data collected from panelists is critical:
1. Panels must be managed in accordance with applicable data protection laws and regulations.
2. Personal or sensitive data should be collected and treated as specified in the Financial Advisor Personal Data Classification Appendix.
3. Upon panelist request, the panelist must be informed of all personal data (relating to the data provided by the Panelist) maintained by FinancialAdvisorsnet. Any personal data that is indicated by the panel member as not correct or obsolete must be corrected or deleted as soon as practicable.
6. Panel members must be given a straightforward method for being removed from the panel if they choose. A request for removal must be completed as soon as practicable and the panelist must not be selected for future research studies.
7. A privacy policy relating to the use of data collected from or relating to the panel member must be in place and posted online. The Privacy Policy must be easy to find and use and must be regularly communicated to panelists. Any changes to the privacy policy must be communicated to panelists as soon as possible.
8. FinancialAdvisorsnet will take steps to limit the number of email survey invitations sent to panel members so as to avoid harassment and response bias caused by the repeated recruitment and participation by panel members.
9. FinancialAdvisorsnet carefully selects panelists that appropriately fit research objectives and Client requirements. All panel members satisfy the requirement that survey participants have either opted-in for research or have a reasonable expectation that they will be contacted for research.
10. FinancialAdvisorsnet manages its panel to achieve the highest possible research quality. This includes managing panel churn and promptly removing inactive panelists.
11. FinancialAdvisorsnet maintains survey identities and email domains that are used exclusively for research activities.
12. All data collected on behalf of a Client must be kept confidential and not shared or used on behalf of another Client.
4. Privacy Laws and Regulations
1. FinancialAdvisorsnet complies with existing state, federal, and international statutes and regulations governing privacy, data security, and the disclosure, receipt and use of personally-identifiable information (collectively "Privacy Laws").
2. In instances in which privacy laws apply to Survey Research operations for specific industries or respondent source, FinancialAdvisorsnet will:
1. Always enter into a confidentiality or "chain of trust" agreement when receiving and using legally protected, personally-identifiable information from a source other than the data subject, insuring that FinancialAdvisorsnet will protect the information and only use it for the purposes specified in the agreement;
2. Always store or maintain personally-identifiable information in a verifiably secure location;
3. Always control and limit accessibility to personally-identifiable information;
4. Always use reasonable efforts to destroy personally-identifiable information once the survey is complete and validation has been conducted, unless the personally-identifiable information relates to Respondents in panels, to ongoing studies, or for some other critical research reason, or the Client is legally or contractually obligated to require its service providers to maintain such information for a certain period of time and contractually imposes this requirement on FinancialAdvisorsnet;
5. Never knowingly receive, use or disclose personally-identifiable information in a way that will cause FinancialAdvisorsnet or another party to violate any Privacy Law or agreement.
3. FinancialAdvisorsnet will, to the extent required by law or as necessary to fully and completely comply with the principles set forth in the section entitled Responsibilities to Financial Advisor Respondents, adopt effective and comprehensive and operational policies which will be updated as necessary to conform with additions to and changes in Privacy Laws.

A. Relationships between FinancialAdvisorsnet and Clients for whom the surveys are conducted are characterized by honesty and confidentiality.

A. When reports are prepared for Client confidential or public release purposes, it is the obligation of FinancialAdvisorsnet to insure that the findings released are an accurate portrayal of the survey data, and careful checks on the accuracy of all figures are mandatory.