Compliance Policies

1. Compliance Framework

Quantum Signals operates under a voluntary compliance program modeled on FINRA-standard research practices for independent research firms, even though Quantum Signals is not a FINRA member and does not operate as a registered broker-dealer or investment adviser.

We adopt these standards voluntarily because our readership includes institutional investors, asset managers, hedge funds, and other sophisticated financial professionals who require assurance that the analysis they receive is produced under rigorous editorial and ethical controls.

Our compliance framework is designed around three principles:

• Independence: Analysis is produced free from financial conflicts of interest with any covered company
• Accuracy: Claims are grounded in primary scientific sources, regulatory filings, and verifiable data
• Transparency: All material disclosures are made proactively and without obfuscation

2. Annual Compliance Training

All individuals involved in the production and distribution of Quantum Signals content complete an annual compliance training program. Training covers the following subject areas:

• Material Non-Public Information (MNPI): Identification of MNPI; procedures to avoid inadvertent receipt or use of MNPI; firewall protocols between personal trading activities and publication timelines
• Regulatory Risk: Overview of securities regulations applicable to independent research publishers; understanding of the boundary between editorial commentary and regulated investment advice; understanding of safe-harbor provisions for bona fide journalistic and educational publications
• Cybersecurity and Data Handling: Protection of pre-publication content; secure handling of subscriber data in compliance with applicable data protection laws; incident response procedures
• Conflicts of Interest: Recognition, disclosure, and management of actual and potential conflicts of interest
• Copyright and Intellectual Property: Obligations when citing, quoting, or linking to third-party sources; fair use boundaries; protection of Quantum Signals' own intellectual property

Training records are maintained and reviewed as part of our annual compliance review cycle.

3. Personal Trading Restrictions

To preserve editorial independence and prevent any actual or perceived conflicts of interest, Quantum Signals imposes personal trading restrictions on its authors and key contributors:

• Pre-publication blackout: No covered security may be traded in personal accounts during the period beginning when a substantive discussion of that security is initiated in the drafting process and ending 48 hours after the relevant issue is published to subscribers
• Disclosure obligation: Any personal holdings in covered securities that exist outside of blackout periods must be disclosed proactively within the relevant newsletter issue
• No front-running: Publication timing is never arranged to benefit personal trading positions; publication is based exclusively on editorial readiness
• Sector ETFs and indices: Broad-based quantum computing ETFs and index instruments are permitted without restriction, provided they do not constitute a significant concentrated position in a covered company
• Private placements and advisory roles: Authors are prohibited from accepting advisory compensation, equity stakes, or other remuneration from any company covered in the Service

Compliance with this trading policy is monitored on an ongoing basis. Any inadvertent breach is required to be disclosed promptly and addressed.

4. Publication Review Process

Each Quantum Signals issue undergoes a structured pre-publication review before distribution to subscribers. This review process is designed to ensure factual accuracy, appropriate tone, proper disclosures, and compliance with our editorial standards.

The review process includes the following steps:

• Factual verification: Technical claims are reviewed against primary sources, including academic papers, patent filings, company regulatory disclosures (10-K, 10-Q, 8-K), and earnings transcripts. Unverifiable claims are either sourced or removed
• Conflict check: Each issue is reviewed to identify any covered security in which the author holds a personal interest; applicable disclosures are added to the issue
• Language review: Content is reviewed to ensure it reads as commentary and opinion rather than investment advice. Language such as "buy," "sell," "hold," or "recommend" is used in a clearly editorial and analytical context, not as a regulated recommendation
• Legal compliance check: Review of any legal claims, regulatory references, or statements about regulatory filings for accuracy and appropriate framing
• Final approval: The issue is cleared for distribution only after the above checks are satisfied

5. Commentary vs. Investment Advice

The regulatory distinction between independent editorial commentary and regulated investment advice is central to our operating model. We maintain this distinction carefully.

Quantum Signals content is editorial commentary. When we describe a company's technology as promising or deficient, when we note that a stock appears overvalued or undervalued relative to its technical reality, or when we use shorthand language such as "bullish" or "bearish" to characterize our assessment of a company's technological position, these are editorial characterizations — the expression of a scientifically-grounded analytical view. They are not, and should not be interpreted as, regulated buy/sell/hold recommendations or personalized investment advice.

This distinction is well-established in U.S. securities law. General circulation publications providing impersonal investment-related commentary based on publicly available information, and directed at all subscribers rather than tailored to any individual's financial situation, are not considered investment advisers under the Investment Advisers Act of 1940.

Quantum Signals is a general circulation publication of this type. We provide analysis for a sophisticated readership. We do not know your financial situation, risk tolerance, time horizon, or investment objectives — and we do not provide advice tailored to any of these factors. All investment decisions remain solely your responsibility.

6. Source Integrity and Independence

Quantum Signals relies exclusively on publicly available information. We do not solicit, receive, or use material non-public information in our analysis. Our sources include:

• Peer-reviewed academic publications in quantum computing, physics, and related disciplines
• Patent filings and intellectual property records (USPTO, EPO, WIPO)
• Public regulatory filings with the U.S. Securities and Exchange Commission (SEC) and equivalent international bodies
• Conference presentations and technical demonstrations at recognized academic and industry venues
• Published earnings calls, investor presentations, and company press releases
• Public benchmarking results and independently reproduced experimental data

We do not accept payment from any company for coverage, favorable positioning, or any other form of consideration that would influence our editorial output. We do not participate in sponsored research or advertising arrangements.

7. Technology Readiness Level (TRL) Disclaimer

Quantum Signals publications occasionally reference Technology Readiness Level ("TRL") assessments when evaluating the technical maturity of quantum computing technologies and the companies developing them. All TRL assessments published by Quantum Signals represent the unofficial editorial opinion of Quantum Signals and its authors, and nothing more.

TRL is a systematic measurement framework originally developed by NASA to assess the maturity of a given technology. The use of TRL terminology or scoring in our content is purely analytical and editorial. Quantum Signals is not affiliated with, endorsed by, sanctioned by, or in any way connected to NASA, the U.S. Department of Defense (DoD), or any other government agency, government-affiliated body, or government-sponsored research organization.

No government agency or department has reviewed, approved, certified, or otherwise validated any TRL assessment appearing in Quantum Signals publications. Our TRL assessments are formed independently, based exclusively on publicly available scientific literature, patent records, regulatory filings, and disclosed experimental data. They should not be interpreted as official, certified, or government-sanctioned technology evaluations.

8. Subscriber Data and Privacy

Subscriber data, including email addresses and payment information, is handled with strict confidentiality. We collect only the minimum data necessary to operate the Service. We do not sell, rent, or share subscriber personal data with third parties, except as required by law or to facilitate payment processing through our payment provider.

Subscriber lists are maintained securely and are not disclosed to any covered company, industry body, or other third party.

9. Trading & MNPI Policy

Quantum Signals does not use, receive, solicit, or facilitate the exchange of material non-public information ("MNPI"). Per SEC guidance, MNPI is information that is not publicly available and that a reasonable investor would consider important when making an investment decision. Examples include unreleased earnings figures, pending mergers or acquisitions, undisclosed partnerships, and proprietary technical benchmarks not reflected in any public filing.

All analysis published by Quantum Signals is based exclusively on publicly available information: SEC filings, published academic papers, patent records, press releases, conference presentations, and public roadmaps. Subscribers and advisory clients must not share MNPI with Omar Shehab or Quantum Signals during calls, by email, or through any other communication.

If MNPI is inadvertently disclosed during any interaction, Quantum Signals will:

• Immediately terminate the conversation or communication in which the disclosure occurred
• Document the incident in our compliance records
• Not use the information in any analysis, publication, or advisory output

Advisory Call Protocol

Advisory sessions are conducted exclusively on the basis of publicly available information. Quantum Signals provides a verbal MNPI disclaimer at the start of every advisory call. A written acknowledgment is included in each booking confirmation email. Clients are encouraged to review this policy and consult their own compliance teams before participating.

Trading Window & Positions Disclosure

Omar Shehab may hold positions in companies covered by Quantum Signals. Any personal holdings in a covered company will be disclosed within the relevant newsletter issue at the time of coverage. Quantum Signals applies the personal trading restrictions described in Section 3 above, including a pre-publication blackout on trading covered securities.

Conflicts of Interest

Quantum Signals is independently operated. We receive no compensation from any company we cover. Advisory fees are the sole revenue from client relationships. No advertiser, sponsor, or covered company has any editorial influence over our content.

MNPI and compliance inquiries may be directed to: omar@quantumsignals.co

10. Reporting Compliance Concerns

We take compliance obligations seriously. If you believe you have identified a potential compliance issue — including a conflict of interest, use of non-public information, inaccurate factual claims, or any other matter — we encourage you to contact us directly.

Compliance inquiries may be directed to: compliance@quantumsignals.co

We will review all reports in good faith and respond where appropriate.