Morningstar’s Editorial Policies

It’s core to Morningstar’s culture to put the investor first, which means we follow a set of rules designed to maintain the independence and objectivity of our analyst/editorial staff.

Business Relationships

To help maintain the integrity of Morningstar’s investment research, there is a strict functional separation between the fund and stock analyst groups (including for this purpose any employee who produces editorial content) on the one hand, and the company’s sales teams on the other. Except as described below, sales personnel may not contact individual analysts directly. Instead, in the United States, all requests must be funneled through the head of securities analysis, the director of fund analysis, or the director of stock analysis. Outside of the United States, all requests must be funneled through the local head of research, editorial director for the relevant publication, or the local country manager. Sales personnel hired specifically to promote access to the stock analyst group may contact individual stock analysts solely in connection with those sales efforts. Most importantly, there must never be any explicit or implied pressure applied by anyone outside the relevant analyst group to influence or change the opinions or conclusions reached in analyses (including editorial content) or research projects. Morningstar’s institutional clients are not given preferential access to fund analysts, and sales personnel are prohibited from setting up meetings between fund analysts and institutional clients or potential institutional clients.

Again, maintaining objectivity and editorial freedom is essential for Morningstar to keep its position of respect in the investment community.

Restricted Securities

To avoid conflicts of interest, Morningstar maintains the following policies on employee stock ownership. These policies apply to employees and their immediate family members:

• We prohibit members of Morningstar’s fund groups from owning the securities of publicly traded companies that derive a significant portion of their revenue from managing mutual funds and that are included on a list of such companies assembled by our Securities Trading and Disclosure Policy Committee.
• Subject to the limited exceptions described below, we prohibit Morningstar stock and corporate credit analysts from holding positions in any company they cover or any of that company’s close competitors. The Securities Trading and Disclosure Policy Committee may waive these restrictions if the company is large, liquid, and well covered, if there is an absence of suitable alternative companies within the analyst’s local market, or if the analyst’s coverage is unlikely to influence the price of the competitor’s securities. Any security purchased upon the grant of a waiver permitted by this section must be held for at least six months, and while the analyst holds the security, all of their reports regarding the company or concerning the competitor, as the case may be, must disclose the holding. The Securities Trading and Disclosure Policy Committee has also determined that the prohibition will not apply to the holding of an immaterial number of shares (fewer than 10) for commemorative purposes.
• To ensure that our customers are the first to benefit from our research, whenever a stock or corporate credit analyst begins researching a stock, we put it on our restricted list. Any stock on this list is off-limits to all members of Morningstar’s equity research and corporate credit research groups and their immediate families. The stock remains on the restricted list until two business days after we publish the report.

Disclosure of Ownership

If an analyst or staff writer mentions a stock they own, we disclose that fact in any editorial piece that mentions the security.