Conflicts of Interest & Position Disclosures

Effective 2026-09-01

Short version. We believe that RockTurners' Service does not constitute acting as an investment adviser under the Investment Advisers Act of 1940 or Colorado law. We publish impersonal research; we do not advise specific clients on their specific accounts. For that posture to hold, our commentary has to be disinterested. This page documents how we keep it that way.

1. Who this applies to

"We" in this document refers to RockTurners, LLC, which operates the website at rockturners.com and the connected web application at rockturners.com/app/ (collectively, the "Service"), currently as a pre-release research preview. "Covered Persons" means RockTurners, LLC together with anyone who can materially influence what the Service publishes — today, its operators and contributors. RockTurners, LLC engages no outside contractors or advisers at present; if that changes, anyone with that same influence becomes a Covered Person and this policy applies to them on the same terms.

2. Personal securities holdings

Most analysis on RockTurners is generated on demand: you choose a strategy, you run it, and the result belongs to your account. We do not publish that output to anyone else, and the rules in this section do not apply to it.

Some analysis we do publish. RockTurners periodically runs its own built-in strategies as sweeps and surfaces those results to every subscriber through the Opportunities feed. We choose when those sweeps run, which strategies they use, and that their results are shown broadly — so the rules below apply to them.

Position disclosure. Where a sweep we publish surfaces a security in which a Covered Person holds a position of more than $10,000 (or more than 1% of issued-and-outstanding shares, whichever comes first), we will disclose that position on request. Email [email protected] and we will tell you whether any Covered Person holds a position in a security the feed has surfaced.
No trading around a sweep. Covered Persons do not transact in a security within 48 hours before or after a sweep we publish first surfaces it.
No coordinated publish-and-sell. We do not time the release of a sweep to the transaction activity of any Covered Person.

We do not otherwise restrict personal investing by Covered Persons — that would be unworkable for a small team, and it is not where the risk sits. The risk is publishing a result broadly while holding a position in it, and that is what the rules above address.

3. Paid placements, sponsored content, affiliates

No paid placements. No issuer, PR firm, or third-party pays to have a specific stock ticker analyzed, ranked, or surfaced by the Service.
No affiliate links. The site carries no broker, custodian, or tax-software referral links, and analysis output contains no revenue-linked references.
If that ever changes — e.g., an explicitly labeled sponsored research section — the label will be visible on the content itself, before the body renders, rather than disclosed only in a footer.

4. No personalized mode — for anyone

The Service produces the same impersonal, methodology-fit output for every account, including accounts belonging to operators and Covered Persons. An earlier pre-release prototype included a founder-only personalized analysis feature; that feature was removed from the platform and no personalized output path exists for any account. No account — operator or user — receives buy/hold/sell ratings or output conditioned on the account holder's holdings or circumstances.

5. Human-in-the-loop on model output

All AI-generated output is framed, rendered, and post-scrubbed against advice-verb patterns before publication. See our AI Disclosure for the architectural details. The purpose of that posture is to keep the publication disinterested and impersonal — the controls exist regardless of what the underlying model happens to produce.

6. Corrections & right of reply

If you are an issuer, investor relations contact, or third party who believes the Service's research about you or your securities contains a material factual error, email [email protected]. We log every request, respond within 5 business days with a determination, and publish corrections on the same analysis page that carried the original content. We do not remove negative analysis in response to request alone; removal requires a material factual error, a security being delisted, or a legal demand we reasonably conclude is correct.

7. What we do not do

We do not hold or have discretion over user funds.
We do not route orders to any brokerage.
We do not provide personalized investment advice to any user or account.
We do not seek information from our users regarding their financial and other circumstances and we do not perform any analysis of the suitability of any particular stock for any user.
We do not accept performance-based compensation from any user or third party.

8. Contact

Conflict-of-interest questions, factual corrections, and everything else: [email protected]

This page describes operating policy, not a safe harbor. Nothing here creates a duty running to any third party beyond what is imposed by applicable law.