1. Focus on Public information and general industry insights
Avoid asking for sensitive, company-specific details for example revenue, contracts, M&A plans or internal strategies. When doing so, frame questions in general terms.
Compliant Example
Non-Compliant Example
‘What trends are you seeing in pricing strategies for companies like Company X?’
'What was Company X's pricing strategy last quarter?'
Flag to CP
2. Indicate use of public information
Explicitly remind the experts to speak only to publicly available data or from their own opinion or experience.
Compliant Example
Non-Compliant Example
‘Citing only public information, how are companies retaining clients in this sector?’
‘What specific client retention strategies does company X use?’
Flag to CP
3. Avoid speculation or leading questions
Do not assume facts or ask about future company actions that are not in the public domain
Compliant Example
Non-Compliant Example
How likely is Company X to acquire another competitor within the next year?
What trends are you seeing in M&A or consolidation activity among companies in this industry?
Flag to CP
4. Promote neutral and balanced coverage
Emphasize objectivity and avoid questions that would prompt the expert to give biased insights.
Compliant Example
Non-Compliant Example
- In your opinion, how does Company X compare to industry peers?
- What does customer churn look like in Industry X and what are the primary reasons why a customer may decide to churn?
- What are Company X's limitations?
- To what extent does Company X risk losing customers to its competitors?
Flag to CP
5. Avoid prompting discussion of the anchor company’s PE owner
We carefully manage coverage of clients and their underperforming portfolio companies to protect client interests and relationships.
Compliant Example
Non-Compliant Example
'With backing from EQT and ChrysCapital, how do you think about the eventual exit pathway—do you see the IPO as a stepping stone to strategic sale, secondary exits, or longer-term build?'
'In your opinion, how do you view an IPO as a longer-term growth strategy?'
Flag to CP
Why take this step?
Poor client feedback or failed red herring tests carries a much higher risk of fraud or future withdrawal
Correctly setting up Research projects ensures that we don't bypass any internal compliance approvals built into the system. This is particularly important for MTs as:
- There are two compliance approval checklist items and
- CP1/DG are required to be approved by RC prior to the call taking place.
This ensures that the experts, moderators and the discussion guides adheres to our internal Research policies, delivering high-quality and safe Research to our clients.
What has this escalation brought to light?
- There is a heightened Sensitivity in Client Portfolio Companies
- We should ensure neutrality in MT Titles, Agendas, and Questions
What we did:
- Audited all Research related to Company Z on AlphaNow.
- No statements found that matched client’s concerns.
- On the contrary, most experts mentioned their clients being regulated clients.
As a reminder: Bain's Compliance team will automatically receive an email with every calendar invite with the necessary CID information
Cross-reference the expert’s LinkedIn (or local platform) while you’re on the phone confirming career history and leave a comment if their profile does not match their career history. It is imperative our records of expert career history are accurate
Stay alert, have a critical eye, and do not go on auto-pilot!
Following the client's flag and our audit, they were particularly concerned with a specific Moderated Call "which reads as most negative / inaccurate based on the summary / topics covered"
MT Title: Company Z: Spotlight on Outdated Infrastructure and Compliance Risks Discussion Topics:
- Company Z's interest rate dependence, high operational costs, and customer concentration risks
- Payment rail outages, outdated tech infrastructure, and data management inefficicencies
- Challenges in maintaining banking licenses, improving AML control, and complying with PSD3 and MiCA reporting requirements
- Competitive fee compressions, brand protection efforts and outlook on liquidation endeavors
You must always tag the correct featured companies of the project to accurately determine the expert's eligibility to participate in an interaction. How to find out what is the featured company:
Company Spotlight Research
The company which is the focus of the MT should be added as the anchor company.
Market Overview Research
All key market players that are being covered/discussed in detail should be added as anchor companies.
Client X raised some concerns over the coverage we did on Company Z. It was one of the client's portfolio companies and they were exploring the sale of their majority stake in the company at the time of the escalation. “Our primary concern relates to statements made regarding the risk profile / industries of Company Z's customers, (...) leading us to believe that the experts in question either fundamentally lack knowledge in that specific area and are relying on a faulty rumor-mill, or worse, are stating these facts with malicious intent… We would be very grateful if you could look through your records to check whether similar statements on Company Z have been made by any expert(s) on your platform. If so, please let us know i) the extent of the spread, ii) other consistent and highly negative unsupported statements made by the same expert(s) so that we can manage it proactively on our end as well.”
Accurate labels are crucial to ensure that all participants go through the correct set of Terms. Please look at the key differences between the moderator and expert Terms.
Terms
Expert
- Goes through TOE and additional Research Terms
- Should go through every new project unless it falls within the same scope with 6 months validity
Moderator
- Goes through Moderator Terms (aka Consultancy Terms)
- Valid for 3 months
Compliance Training
Moderator
- 13 questions
- Passing rate of 80% with three attempts
- Valid for 3 months
Expert
- 6 questions
- No passing rate
- Valid for 12 months
What classifies as not representive?
- Niche product of the target
- Limited and anecdotal use cases
- Insufficent understanding and responses
RC CP Week Day 1 LMS
Anna Hentunen
Created on November 3, 2025
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Transcript
1. Focus on Public information and general industry insights
Avoid asking for sensitive, company-specific details for example revenue, contracts, M&A plans or internal strategies. When doing so, frame questions in general terms.
Compliant Example
Non-Compliant Example
‘What trends are you seeing in pricing strategies for companies like Company X?’
'What was Company X's pricing strategy last quarter?'
Flag to CP
2. Indicate use of public information
Explicitly remind the experts to speak only to publicly available data or from their own opinion or experience.
Compliant Example
Non-Compliant Example
‘Citing only public information, how are companies retaining clients in this sector?’
‘What specific client retention strategies does company X use?’
Flag to CP
3. Avoid speculation or leading questions
Do not assume facts or ask about future company actions that are not in the public domain
Compliant Example
Non-Compliant Example
How likely is Company X to acquire another competitor within the next year?
What trends are you seeing in M&A or consolidation activity among companies in this industry?
Flag to CP
4. Promote neutral and balanced coverage
Emphasize objectivity and avoid questions that would prompt the expert to give biased insights.
Compliant Example
Non-Compliant Example
Flag to CP
5. Avoid prompting discussion of the anchor company’s PE owner
We carefully manage coverage of clients and their underperforming portfolio companies to protect client interests and relationships.
Compliant Example
Non-Compliant Example
'With backing from EQT and ChrysCapital, how do you think about the eventual exit pathway—do you see the IPO as a stepping stone to strategic sale, secondary exits, or longer-term build?'
'In your opinion, how do you view an IPO as a longer-term growth strategy?'
Flag to CP
Why take this step?
Poor client feedback or failed red herring tests carries a much higher risk of fraud or future withdrawal
Correctly setting up Research projects ensures that we don't bypass any internal compliance approvals built into the system. This is particularly important for MTs as:
- There are two compliance approval checklist items and
- CP1/DG are required to be approved by RC prior to the call taking place.
This ensures that the experts, moderators and the discussion guides adheres to our internal Research policies, delivering high-quality and safe Research to our clients.What has this escalation brought to light?
What we did:
As a reminder: Bain's Compliance team will automatically receive an email with every calendar invite with the necessary CID information
Cross-reference the expert’s LinkedIn (or local platform) while you’re on the phone confirming career history and leave a comment if their profile does not match their career history. It is imperative our records of expert career history are accurate
Stay alert, have a critical eye, and do not go on auto-pilot!
Following the client's flag and our audit, they were particularly concerned with a specific Moderated Call "which reads as most negative / inaccurate based on the summary / topics covered"
MT Title: Company Z: Spotlight on Outdated Infrastructure and Compliance Risks Discussion Topics:
You must always tag the correct featured companies of the project to accurately determine the expert's eligibility to participate in an interaction. How to find out what is the featured company:
Company Spotlight Research
The company which is the focus of the MT should be added as the anchor company.
Market Overview Research
All key market players that are being covered/discussed in detail should be added as anchor companies.
Client X raised some concerns over the coverage we did on Company Z. It was one of the client's portfolio companies and they were exploring the sale of their majority stake in the company at the time of the escalation. “Our primary concern relates to statements made regarding the risk profile / industries of Company Z's customers, (...) leading us to believe that the experts in question either fundamentally lack knowledge in that specific area and are relying on a faulty rumor-mill, or worse, are stating these facts with malicious intent… We would be very grateful if you could look through your records to check whether similar statements on Company Z have been made by any expert(s) on your platform. If so, please let us know i) the extent of the spread, ii) other consistent and highly negative unsupported statements made by the same expert(s) so that we can manage it proactively on our end as well.”
Accurate labels are crucial to ensure that all participants go through the correct set of Terms. Please look at the key differences between the moderator and expert Terms.
Terms
Expert
Moderator
Compliance Training
Moderator
Expert
What classifies as not representive?