The following code of conduct applies to all employees and/or other analysts working on material published by Akkur – Greining og ráðgjöf ehf. (“AKKUR”).
AKKUR’s research is prepared in accordance with EU Regulation No. 596/2014 on market abuse and Commission Delegated Regulation (EU) No. 2016/958.
Employees of AKKUR shall act with integrity and professionalism and avoid conflicts of interest. Objectivity shall be maintained in the preparation and publication of all material.
AKKUR’s research shall be based solely on public information from reliable sources. “Reliable sources” means the issuers of the securities themselves, public institutions, ministries, and other such parties.
Research shall be carried out using recognised methods, and the methodology shall be stated in each case, together with the principal assumptions underlying the analysis. Where different methods or assumptions are used in analysing the same security, this shall be specifically noted. Research on securities shall be independent of the issuers of those securities. Research shall be dated, and the name of the author or authors shall be clearly stated.
Employees of AKKUR are prohibited from holding a net long or short position exceeding 0.1% of the issued share capital of an issuer on which AKKUR publishes research.
Employees of AKKUR are prohibited from trading in a security during the 30 days before and the 7 days after the publication of research on that security.
Where employees of AKKUR trade in a security within the limits of these rules, this shall be disclosed in the next research publication on that security.
Should a conflict of interest arise between employees of AKKUR and an issuer that casts doubt on AKKUR’s impartiality, AKKUR shall disclose the conflict of interest and, where appropriate, cease publishing research on the issuer’s securities.
This code of conduct shall be updated as deemed necessary, and no less than annually.
As adopted by the board of Akkur – Greining og ráðgjöf ehf. on 23 December 2025.