Compliance

MARA will adhere to strict compliance and ethical standards, mirroring best practices from the Pharmaceutical Industry. 

We will never:

• Use or share non-public “insider” information inappropriately: All team members operate under NDA; no leaking of deal information or the target’s sensitive data. We avoid even the appearance of insider trading – e.g. we won’t trade any securities related to clients, and we base our reports on information that is either public or provided under proper NDA walls.
• Solicit or obtain embargoed payer decisions or confidential HTA advice: We do not reach out to HTA bodies or payers to get an “advance read” on a pending submission. Any payer insight must come through public channels or properly blinded expert elicitation – never through off-the-record promises. This ensures we don’t cross into lobbying or misuse privileged regulatory information.
• Engage in advocacy or influence-peddling: MARA maintains a clear line between independent analysis and advocacy. No lobbying of payers, no “friendly calls” to get a better price, and no participation in formal negotiations with payer authorities. We advise clients what to expect, but do not attempt to change the outcome. This keeps our role clearly unbiased.
• Rely on company-provided optimistic scenarios: If a client or seller provides internal projections or a Target Product Profile that is rosy, we will note it but our analysis will reset to objective benchmarks. MARA does not simply validate a client’s best-case scenario; we rebuild assumptions from the ground up using evidence. No inclusion of assumptions that can’t be supported by external data or expert consensus (to avoid wishful thinking tainting our conclusion).
• Violate antitrust/competition law during analysis: In multi-party deal situations (e.g. consortia or if advising a seller on broad market trends), we use “clean team” principles. We won’t facilitate inappropriate information exchange about future pricing or market strategies between competitors. For example, we wouldn’t share one bidder’s price intentions with another or with any payer. All analyses are kept confidential to the client, and any market-sensitive data is handled in aggregate or anonymized form to stay onside of competition regulations.
• Act as investment advisors or guarantee outcomes: Our report is an informed opinion, not a guarantee or a recommendation to invest or not invest in a security. We stop short of saying “Do the deal” or “Don’t do it” – instead we objectively state the reimbursement feasibility and risk. We avoid language that could be construed as certifying the investment itself. This ensures we don’t need regulatory registration as a ratings agency or financial advisor. The ultimate decision lies with the client; we provide one vital input.
• Take on conflicts of interest: We will decline engagements that present a conflict, such as advising two competing buyers on the same asset. We also avoid contingent fee structures tied to deal success that could bias our work. Our independence is our credibility – much like an auditor or fairness opinion provider, once we sign on to a project we serve only that client’s interest in objective analysis.
• Overstep professional boundaries or local compliance codes: We ensure any expert consultants we use are free of their own conflicts (e.g. a recent ex-payer subject to “cooling off” periods won’t be engaged on his former agency’s area to respect revolving-door rules). We also follow all applicable laws on consulting with healthcare stakeholders (e.g. if a country bans pre-approval advice from current officials, we won’t do it even under hypothetical guise). When in doubt, we seek legal counsel to vet our approaches (for example, to confirm that issuing a “Market Access Risk Score” doesn’t inadvertently trigger any regulatory oversight).