Disclosure

Who I am

Lucian Mesaroș, an individual investor based in Romania. I am the sole author of everything published here; no one else is involved in producing a valuation. My job title, for the purposes of Article 2 of Commission Delegated Regulation (EU) 2016/958, is independent equity analyst. I publish in a personal capacity, as an individual — there is no company behind this publication, no employer, no group, and no one else with an interest in what it says.

What I am not

I am not authorised, licensed, registered or supervised by the Autoritatea de Supraveghere Financiară (ASF) or by any other financial supervisory authority, in Romania or anywhere else. I am not an investment firm, a fund, an asset manager, a broker or a financial adviser. I hold no professional certification — no CFA, no ASF certificate, no equivalent. I am self-taught, and I say so on purpose.

What this publication is

I estimate what companies are worth, mostly using discounted cash flow analysis in the tradition of Aswath Damodaran, and I publish the estimate against the market price along with the model behind it. Under EU law this makes what I publish an investment recommendation within the meaning of Article 3(1)(35) of Regulation (EU) No 596/2014 — an opinion as to the value of a financial instrument — even though I do not tell anyone to buy or sell anything. I comply with Article 20 of that Regulation and with Commission Delegated Regulation (EU) 2016/958 on that basis.

What this publication is not

Nothing here is investment advice and nothing here is a personal recommendation. I do not know who you are, what you own, what you earn, how long you can hold, or what you can afford to lose, and I do not want to know. Everything is published identically to every reader, at the same moment, whether they pay or not. Nothing is tailored to anyone, and nothing may be relied on as though it were. If you want advice about your own situation, an authorised adviser is the right person to ask, and I am not one.

This applies to companies published in response to a subscriber request as much as to any other. A request tells me what to look at. It does not make the answer personal to whoever asked, and the answer is always published to everyone.

My positions

I invest my own money in some of the companies I value. That is deliberate — it is the point of the publication, and I would not trust an analyst who had nothing at stake. It is also a conflict of interest, so:

• Every valuation states whether I own the shares, as at its publication date, and that statement covers shares held by persons closely associated with me within the meaning of Article 3(1)(26) MAR — spouse or equivalent partner, dependent children, relatives who have shared my household for at least a year, and any entity I control.
• Position disclosures are frozen at publication. If my position changes, that appears in a new valuation, not as an edit to an old one.
• What I Own lists every company I hold, including ones I have never valued and positions I have sold. Sold rows stay visible.
• I disclose separately if any position of mine ever exceeds 0.5% of a company's issued share capital.

How I trade around what I publish

1. I do not trade in a company's shares in the 2 business days before or after I publish a valuation of it. The blackout applies to buying and to selling.
2. I do not sell a position within 30 days of publishing a valuation in which I disclosed owning it, unless something material about the company changed — and if I do, I say so and why, in the next valuation of that company or on the track record.
3. I establish a position before I publish, never after the audience has had time to react to it.
4. I do not trade against what I published while it stands. If I change my mind, the change is published first.
5. No derivatives, no shorting, no options on any company I cover. Nothing that profits from a short-term move.

What I do not do

I have never been paid by a company to value it, and I will not be. I have no agreement with any issuer I write about, of any kind. I do not send drafts to companies for review before publication; if I ever do and then change something as a result, the valuation will say so. I am not a market maker or liquidity provider, I have not underwritten or managed a securities offering, and I provide no services to any company I cover. I accept no advertising or sponsorship from issuers, brokers or anyone with a position in a company I write about. My only revenue is subscriptions paid by readers.

Facts, estimates and opinions

Company figures are as reported in filings, and I say which filing. Everything forward-looking — growth rates, margins, reinvestment, cost of capital, and therefore the value per share itself — is my estimate, and is labelled as one. My estimates are frequently wrong, sometimes badly. Past valuations that turned out well do not indicate that future ones will.

Records

I keep every published valuation, its model, its sources and its date and time of completion, together with the record of my own trades in covered companies. Published valuations are append-only and are never rewritten. Corrections are published as corrections.

The 12-month list

What I've Published is the full record of every valuation I published in the last 12 months — the date and time, the company, my estimate, the market price it was measured against, the direction of the two, and how long each one stands. I am the author of every entry on it; no one else produces a valuation here.

It is published under Article 4(1)(i) of Commission Delegated Regulation (EU) 2016/958, which requires anyone producing investment recommendations to keep such a list publicly available. The list is not edited: a valuation I later disagreed with stays on it, dated.

Complaints and contact

Use the contact form, or email contact@lucianmesaros.ro directly — both reach the same inbox, and I read it myself. If something here is factually wrong, tell me and I will correct it publicly: corrections are published as corrections, not edited in quietly.