Last Updated: May 2026
This Conflicts of Interest Policy describes the standards ZLARK LLC (“ZLARK,” “we,” “us,” or “our”) applies to reduce, disclose, mitigate, and where necessary avoid conflicts that could affect research, market commentary, trade setup analysis, performance discussion, editorial judgment, commercial relationships, or reader trust.
This policy applies to research and editorial content published through zlark.net and related services, including public articles, premium research, watchlists, alerts, trade setup commentary, performance-related materials, presentations, interviews, and other published market communications. This page should be read together with the Research Methodology, Terms of Service, and Privacy Policy.
1. Policy Objective
The objective of this policy is not merely to disclose conflicts after they arise. The objective is to structure ZLARK's research process so that personal, financial, commercial, promotional, and relational incentives do not improperly shape what is covered, how it is analyzed, or how it is presented.
Where a conflict cannot be responsibly managed through separation, disclosure, limitation, or monitoring, ZLARK may decline coverage, restrict participation, or refrain from publishing on the affected subject altogether.
2. Core Independence Principle
ZLARK research and commentary are intended to reflect independent analytical judgment. No issuer, sponsor, advertiser, subscriber, affiliate, platform, or commercial counterparty is entitled to dictate conclusions, suppress unfavorable analysis, pre-approve editorial views, or condition payment or access on a desired outcome.
Commercial relationships, marketing considerations, audience preferences, and social-media incentives must not be permitted to override evidence, distort risk discussion, or convert analysis into undisclosed promotion.
3. Categories of Conflicts Covered
This policy applies to actual conflicts, potential conflicts, and circumstances that create a reasonable appearance of conflict. Relevant categories include personal holdings, family or close-associate holdings, compensation arrangements, outside business activities, issuer relationships, affiliate relationships, referral incentives, gifts and hospitality, media or speaking compensation, access-related benefits, and the use of unpublished research for private gain.
ZLARK treats appearance risk seriously. A situation may be unacceptable even if no improper conduct can be proven, where a reasonable reader could conclude that a published view was materially affected by the conflict.
4. Personal Holdings and Beneficial Ownership
ZLARK or persons contributing to ZLARK research may from time to time hold positions in securities, funds, or other instruments discussed in published content unless a stricter restriction applies. That possibility is not treated as trivial. Whether ZLARK itself, an author, or a contributor has a position is often the most important practical conflict a reader needs to understand when evaluating research.
Where ZLARK, the author, or another person materially involved in the content has a beneficial interest in a specifically named security, ZLARK's policy is to disclose that interest in or near the affected content where practical. If the position is directional, the disclosure should identify whether the exposure is long or short. If no position is held, ZLARK may also state that no relevant position is held where doing so improves clarity.
As a public policy matter, ZLARK may hold positions in securities it discusses, and authors or contributors may also hold positions unless they are subject to a stricter internal restriction or recusal requirement. Such ownership does not by itself invalidate the research, but it requires transparent handling. When a specifically named security is the subject of a report, note, setup, or commentary and a material position is held by ZLARK or by the person principally responsible for the content, the existence of that position should be disclosed at the time of publication.
A beneficial interest is interpreted broadly and may include direct ownership, indirect ownership, household or controlled-account exposure, options or derivative exposure, or another economic interest that could reasonably affect objectivity. Holdings that are remote, de minimis, or not reasonably connected to the analysis may not always require individualized disclosure, but doubtful cases should be resolved in favor of transparency.
5. Restrictions on Trading Around Publication
No person acting for ZLARK may trade to exploit knowledge of unpublished research, unpublished alerts, unpublished watchlist changes, or planned editorial coverage. Front running, shadow trading, signaling positions privately before publication, or using pending ZLARK content for personal timing advantage is prohibited.
Analysts, authors, contributors, and anyone acting for ZLARK may not trade ahead of publication in order to benefit from expected market reaction to pending ZLARK content. ZLARK also may not use publication as a device to accumulate, distribute, enter, exit, or otherwise improve the economics of a position through undisclosed timing advantage.
As a public operating rule, ZLARK should not establish a new position in a named security immediately before publishing content intended to influence or discuss that same security in a meaningful way. Likewise, ZLARK should not publish research as a device to facilitate an immediate exit from a pre-existing position without appropriate disclosure. If a recent trade, planned trade, or active position makes publication timing look self-serving, the proper response is to delay publication, disclose more specifically, or not publish.
Where a position exists at the time of publication and is material to the subject of the content, ZLARK's disclosure practice should identify that the position exists and, where relevant, whether the exposure is long or short. Publication of research does not constitute a solicitation to buy or sell any security, and no reader should assume that ZLARK's timing, liquidity, risk tolerance, or investment horizon matches their own.
Where ZLARK determines that a blackout period, holding-period expectation, pre-clearance workflow, or trade logging process is necessary for a particular product line, contributor, or security type, those controls may be imposed in addition to this public policy. ZLARK may also decline coverage where personal-position timing makes clean publication impractical.
6. Principal Capital and Company Investment Activity
ZLARK may manage its own capital across asset classes, including equities, bonds, ETFs, options, and selected digital assets. This can create an inherent principal-capital conflict when ZLARK publishes research on instruments in which it already has exposure or may seek exposure.
ZLARK may hold positions in securities or instruments it discusses. That is not prohibited by this policy, but it makes disclosure and timing discipline critical. Research involving a specifically named security or instrument must not imply that ZLARK is disinterested if ZLARK has a material economic exposure to the subject at the time of publication.
Accordingly, where ZLARK holds a material position in a specifically named covered security or instrument discussed in a report or commentary, the report should disclose that ZLARK may hold or currently holds that position, and where practical should indicate whether the exposure is long or short. Research is provided for informational and analytical purposes only and does not constitute a solicitation, personalized recommendation, or instruction to transact.
7. Covered Securities and Recusal
If a contributor's financial interest, recent trading activity, family relationship, commercial connection, advisory role, board role, compensation arrangement, or other material interest is sufficiently close to the subject of the research, recusal may be required. Recusal may include refraining from drafting, editing, approving, or materially influencing the affected content.
Recusal is favored where disclosure alone would not adequately protect the credibility of the work. In some cases, the proper response is not merely to disclose the conflict but to avoid publishing under ZLARK's name until the conflict no longer creates a meaningful objectivity concern.
8. Issuer Compensation and Sponsored Influence
ZLARK does not present paid promotion, issuer-funded favorable coverage, compensation for a predetermined research conclusion, or compensation conditioned on trading activity, financing outcomes, audience conversion, or securities performance as independent research. If content is sponsored, paid, promotional, partner-produced, or otherwise commercially influenced, that fact must be clearly identified.
If ZLARK were to accept compensation connected to a covered issuer, sector participant, product provider, or other financially interested party, the existence, nature, and material relevance of that relationship would need to be assessed for disclosure, separation, or non-publication. Undisclosed pay-for-coverage arrangements are prohibited.
9. Advertising, Sales, and Commercial Separation
Research judgment should be functionally separate from advertising sales, sponsorship discussions, affiliate arrangements, platform partnerships, and other commercial negotiations. Commercial personnel or commercial objectives may inform business priorities, but may not dictate analytical outcomes or pressure research to soften, delay, omit, or manufacture conclusions.
ZLARK may operate as a business, but revenue generation does not excuse compromised independence. Where commercial structures create recurring pressure on research integrity, the structure itself should be revised rather than normalized.
10. Outside Work, Advisory Roles, and Business Relationships
Outside consulting, advisory services, board participation, contractor relationships, strategic partnerships, referral arrangements, or personal business ties may create conflicts if they relate to subjects covered by ZLARK research. Such relationships should be evaluated before publication, not after criticism arises.
Where outside work creates a meaningful risk that research could be influenced, perceived as influenced, or used to benefit a private client or relationship, ZLARK may require disclosure, subject-matter restriction, recusal, or a complete prohibition on the affected coverage.
11. Gifts, Travel, Entertainment, and Access Benefits
Gifts, hospitality, event access, travel reimbursement, premium access, favors, or other benefits from issuers, promoters, funds, brokers, exchanges, vendors, lobbying groups, political actors, or other interested parties must not create a sense of obligation or a reasonable perception that favorable treatment was purchased.
ZLARK should avoid accepting benefits that are excessive, non-routine, luxury-oriented, contingent on coverage, or difficult to defend publicly. When a benefit is accepted for a legitimate operational reason, its relevance to objectivity should still be assessed for disclosure, limitation, or avoidance of the related coverage.
12. Speaking, Media Appearances, and Public Commentary
Appearances on podcasts, broadcasts, conferences, webinars, panel discussions, and similar events may create conflict concerns if compensation, host affiliation, issuer sponsorship, or event structure encourages advocacy rather than analysis. Paid appearances relating to covered securities, sectors, or counterparties should be approached conservatively.
ZLARK should not accept fees, reimbursements, or promotional benefits that would reasonably call into question the independence of subsequent commentary on the relevant subject. Public commentary outside zlark.net should also remain consistent with ZLARK's disclosure, objectivity, and no-front-running standards.
13. Confidential and Nonpublic Information
ZLARK does not permit the use of material nonpublic information, misappropriated information, leaked confidential deal information, or privileged access obtained through a duty of confidence for trading, tipping, or publication. Research should be built on lawful and ethically usable information sources.
If information appears confidential, selectively disclosed, improperly obtained, or likely to expose ZLARK or readers to legal or ethical risk, the proper course may be to stop, verify, escalate, and avoid publication or use pending further review.
14. Reader-Facing Disclosures
When a conflict is material to a reasonable reader's evaluation of the content, ZLARK should disclose it clearly and in proximity to the affected content where practical. Disclosures should be understandable, specific enough to matter, and not buried in a way that defeats their purpose.
A disclosure does not cure every conflict. Some conflicts are too severe, too direct, or too timing-sensitive to be neutralized by disclosure alone. In those cases, limitation, recusal, or non-publication is the appropriate response.
15. Corrections, Changes, and Ongoing Review
Conflicts assessments may need to change over time as holdings change, roles change, new relationships arise, or previously immaterial interests become significant. ZLARK may update disclosures, revise content, add clarifications, or remove material where a conflict was not properly handled at the time of publication.
This policy is intended to evolve with the scope of ZLARK's research operations. Additional internal procedures, stricter product-level rules, or contributor-specific controls may be adopted where needed to keep the public policy effective in practice.
16. No Waiver of Reader Responsibility
This policy is a governance and transparency document. It does not convert ZLARK into a fiduciary, broker-dealer, investment adviser, or personalized recommendation service, and it does not eliminate the need for readers to make independent decisions and review the disclaimers and limitations stated elsewhere on the site.
17. Contact
ZLARK LLC
Registered in the State of Wyoming, United States
Email: [email protected]
Website: https://zlark.net
Questions, concerns, or notices relating to this Conflicts of Interest Policy may be submitted in writing to the email address above.
