LEGAL & COMPLIANCE
BUSINESS CONTINUITY PLAN
As required by securities industry regulations, Tudor, Pickering, Holt & Co. (“TPH” or our “Firm”) wants to make you aware that we have developed a Business Continuity Plan on how we will respond to events that may disrupt our business. Since the timing and impact of disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur.
Our Business Continuity Plan
Significant business disruptions can vary from disrupting only our Firm to the region in which we are located. Our Business Continuity Plan (our “Plan”) addresses various disruptions and is intended to mitigate reasonable risk so as to permit the continuation of key business operations. Our Plan addresses data back-up and recovery, mission critical systems, safeguarding our employees and property, financial and operational assessment, alternative communications with customers, employees and regulators, alternate physical location of employees, critical supplier and bank, and counterparty impact, regulatory reporting and assuring our customers prompt access to their funds and securities and allowing our customers to transact business.
TPH maintains redundant offsite archival storage facilities in a geographically separate area. Our clearing firm, the Broadcort Correspondent Clearing Division of Merrill Lynch, Pierce, Fenner & Smith Incorporated, also backs up certain of our sales and trading records for our Tudor, Pickering, Holt & Co. Securities, LLC subsidiary. We have designated an alternate site to conduct key business operations until we are able to return to our offices. Our Firm’s goal is to recover its critical operations within minutes or hours after the disruption. In the event of a disaster, Tudor, Pickering, Holt & Co. Securities, LLC will provide its customers prompt access to their funds and securities held at its clearing firm.
In the event of a business disruption, TPH will provide important information to its employees and clients via call forwarding, e-mail and postings to our Firm’s webpage located at www.tphco.com. Our address is:
1111 Bagby, Suite 5100
Houston, TX 77002
If you are a sales and trading client of Tudor, Pickering, Holt & Co. Securities, LLC and you are unable to reach us during a business disruption, you may contact our clearing firm, the Broadcort Correspondent Clearing Division of Merrill Lynch, Pierce, Fenner & Smith Incorporated, for trade related information. Their contact information is as follows:
Broadcort Correspondent Clearing Division of Merrill Lynch, Pierce, Fenner & Smith Incorporated
101 Hudson Street
Jersey City, NJ 07302
The plan is subject to modification, an updated summary will be promptly posted on our website, www.tphco.com. Customers may alternatively obtain updated summaries by requesting a written copy by mail. Please direct any such inquiries to the Compliance Department.
TPH’s North American regulated companies covered by our Plan: Tudor, Pickering, Holt & Co. Securities, LLC*.
*Clearing firm services are only applicable to the business services of Tudor, Pickering, Holt & Co. Securities, LLC
In the event you should have a question or complaint that you would like to register with our Firm, please contact the Compliance Department at:
Tudor, Pickering, Holt & Co. Securities, LLC
Attn: Compliance Department
1111 Bagby, Suite 4800
Houston, TX 77002 USA
Tudor, Pickering, Holt & Co. Securities – Canada, ULC
Attn: Compliance Department
Suite 2110, 250 – 6th Avenue SW
Calgary, AB T2P 3H7
© Tudor, Pickering, Holt & Co. 2021. No person may reproduce any portion of the content on this website without prior written consent of Tudor, Pickering, Holt & Co. “Content” refers to any materials, documents, images, graphics, logos, design, audio, video and any other information provided from or on our site.
Email is confidential and is intended only for the individual named. The information contained in an email may not be disclosed, copied or disseminated, in whole or in part, without the prior written permission of Tudor, Pickering, Holt & Co. (“TPH”). Email communications are based on information which Tudor, Pickering, Holt & Co. believes is reliable. However, TPH does not represent or warrant its accuracy. Email messages should not be considered as an offer or solicitation to buy or sell any securities. Securities offered through Tudor, Pickering, Holt & Co. Securities, LLC, Member FINRA/SIPC and Tudor, Pickering, Holt & Co. Securities – Canada, ULC, Member IIROC/CIPF.
Under FINRA Rule 2210, TPH email communications are deemed institutional sales material and are not meant for distribution to retail investors. Recipients should not forward TPH email communications to a retail investor.
INFORMATION SHARING FOR MARKETING PURPOSES
Federal law gives you the right to limit information sharing between affiliated entities for marketing purposes. It also requires us to give you this notice to tell you about your choices to limit information sharing for marketing purposes.
This notice is being provided on behalf of Tudor, Pickering, Holt & Co. Securities, LLC. You may limit our affiliates from marketing products or services to you based on your personal information that they collect and share with one another. This information includes your contact information, account history.
To prohibit information sharing for marketing purposes, please contact the Compliance Department at email@example.com or call collect at 713-333-7100. Your instruction to limit marketing offers from our affiliates will remain in effect until you tell us to make a change.
This website is for informational purposes only and does not constitute an offer to sell or solicitation of an offer to buy any security which may be referenced on this website. Offers can only be made where lawful under applicable law.
Tudor, Pickering, Holt & Co. (“TPH”) considers your privacy our utmost concern. In order to provide you with individualized service, we collect certain personal, non-public information about you from information you provide on applications or other forms and information about your account transactions with us. We may also collect such information through your account inquiries by mail, email, or telephone.
- Use of Your Data. We may use your information for any purpose in our discretion. In general, information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. TPH uses your information for research, marketing, and general purposes; identify you as a user in our system; provide improved administration of our services; improve the quality of experience when you interact with our research reports and services; send you administrative e-mail notifications; respond to your inquiries; send promotional communications; make telephone calls to you, from time to time, as a part of secondary fraud protection; and to solicit your feedback. We may create anonymous data records from information by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our services and improve site navigation. TPH reserves the right to use and disclose anonymous data to third party companies for any purpose in its discretion. If you provide feedback on any of our services to us, we may use such feedback for any purpose, provided we will not associate such feedback with your information.
We do not disclose any nonpublic personal information about you to anyone, except as permitted by law. Specifically, so that we may continue to offer you products and services that best meet your investing needs, and to effect transactions that you request or authorize, we may disclose the information we collect, as described above, to companies that perform administrative or marketing services on our behalf, such as transfer agents, or printers and mailers that assist us in the distribution of investor materials. These companies will use this information only for the services for which we hired them, and are not permitted to use or share this information for any other purpose.
If you decide at any point either to end your relationship with us or to become an inactive customer, we will continue to adhere to the privacy policies and practices described in this notice.
With regard to our internal security procedures, we restrict access to your personal and account information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.
If you should have any questions or comments about our Customer Identification Program, please contact our Compliance Department on 713-333-7100 or 713-333-2960. You may write to us at the following address:
Tudor, Pickering, Holt & Co. Securities, LLC
Attn: Compliance Department
1111 Bagby, Suite 4800
Houston, Texas 77002
SOCIAL MEDIA DISCLOSURES
Tudor, Pickering, Holt & Co. and its affiliated companies (“TPH”) reserve the right to retain, monitor, and reproduce all electronic communications consistent with applicable law. Tudor, Pickering, Holt & Co. is the trade name for Tudor, Pickering, Holt & Co. Securities, LLC, Member of FINRA & SIPC. Neither the information, nor any opinion, nor any other content on this site constitutes a solicitation or offer by TPH or its affiliates to buy or sell any securities, options, or other financial instruments or provide any investment advice or services. TPH will not accept purchase or sales orders via Twitter or any social media systems, and reminds all users not to disclose any personal financial information on Twitter. TPH is not responsible for third parties that may be linked to this page or to other Twitter pages, including but not limited to content posted by third parties, the privacy and security policies of Twitter or any other third-party sites, or for the products or services offered by any third party.
Tudor, Pickering, Holt & Co. and its affiliated companies (“TPH”) reserve the right to retain, monitor, and reproduce all electronic communications consistent with applicable law. Tudor, Pickering, Holt & Co. is the trade name for Tudor, Pickering, Holt & Co. Securities, LLC , Member of FINRA & SIPC. Neither the information, nor any opinion, nor any other content on this site constitutes a solicitation or offer by TPH or its affiliates to buy or sell any securities, options, or other financial instruments or provide any investment advice or services. TPH will not accept purchase or sales orders via LinkedIn or any social media messaging systems, and reminds all users not to disclose any personal financial information on LinkedIn. TPH is not responsible for third parties that may be linked to this page or to other LinkedIn pages, including but not limited to content posted by third parties, the privacy and security policies of LinkedIn or any other third-party sites, or for the products or services offered by any third party. All statements and messages are for U.S. residents only.
Tudor, Pickering, Holt & Co. and its affiliated companies (“TPH”) reserve the right to retain, monitor, and reproduce all electronic communications consistent with applicable law. Tudor, Pickering, Holt & Co. is the trade name for Tudor, Pickering, Holt & Co. Securities, LLC, Member of FINRA & SIPC. Neither the information, nor any opinion, nor any other content on this site constitutes a solicitation or offer by TPH or its affiliates to buy or sell any securities, options, or other financial instruments or provide any investment advice or services. TPH will not accept purchase or sales orders via Facebook or any electronic messaging systems, and reminds all users not to disclose any personal financial information on Facebook. TPH is not responsible for third parties that may be linked to this page or to other Facebook pages, including but not limited to content posted by third parties, the privacy and security policies of Facebook or any other third-party sites, or for the products or services offered by any third party. All statements and messages are for U.S. residents only.
The compensation of Research Analysts is intended to reflect the value of the services they provide to our Firm. As with most other employees, the compensation of Research Analysts is impacted by the overall profitability of our Firm, which may include revenues from corporate finance activities of our Firm’s Investment Banking department. A Research Analyst’s compensation is not, however, directly or indirectly related to any specific investment banking transaction or any recommendation or view expressed in a research report.
Dissemination of Research
Our Firm’s investment research is available to our clients on a confidential basis. Clients of our Firm may request to receive our research reports by email or hardcopy. Requests for access to our research should be sent to the Research Department at TPHEnergyResearch@tphco.com. Senior management of the Securities Department reviews all requests to receive research reports and related information. Approval to receive our Firm’s investment research is based on the given client being in good standing with our Firm and on compliance with regulatory requirements. Our Firm’s research reports are for the exclusive use of the client to which the research report was sent by our Firm and may not be reproduced or redistributed without our Firm’s express written consent.
Investment Banking Revenue
Investment Banking or Other Services
Tudor, Pickering, Holt & Co. has received in the past 12 months or expects to receive within the next 3 months compensation for investment banking or other services from the following companies:
Approach Resources Inc.
Blue Mountain Midstream
Calfrac Well Services
California Resources Corporation
Crescent Point Energy Corp.
Gain Energy Ltd.
Forum Energy Technologies, Inc.
Gulfport Energy Corporation
Highpoint Resources Corporation
JP3 Measurement, LLC
Liberty Oilfield Services, Inc.
Obsidian Energy Ltd
Pembina Pipeline Corporation
Pioneer Natural Resources
Polar Star Canadian Oil and Gas
Rifle Shot Oil Corp.
Riviera Resources, Inc.
Summit Midstream Partners LP
Topaz Energy Corp.
Ultra Petroleum Corp.
We intend to seek compensation for investment banking services from the companies we follow in the next 3 months. A listing of the companies we follow may be found at www.tphco.com/research-coverage/.
Non-Investment Banking Securities-related Services
In the past 12 months, Tudor, Pickering, Holt & Co. has received compensation for non-investment banking securities-related services from:
Hess Corp., through its energy trading affiliate Hess Energy Trading Company, LLC
Managed or Co-managed Public Offerings
Tudor, Pickering, Holt & Co. has managed or co-managed a public offering of securities in the past 12 months for the following companies:
Peridot Acquisition Corp.
Rattler Midstream LP
Material Conflict Disclosure
TPH: John E. Lowe, Senior Executive Advisor, currently serves on the board of Phillips 66 and TransCanada and as non-executive chairman of Apache Corp. John Gibson, Senior Advisor, currently serves on the board of Orocobre (Australia) and serves as the CEO of Flotek. Alexandra Pruner, Senior Advisor, currently serves on the board of Plains All American as independent director.
TPHC: Hilary Foulkes, Senior Advisor, currently serves on the board of Enerplus Corp.
Financial Interest in Research Coverage Universe
Tudor, Pickering, Holt & Co. and its affiliates do not own 1% or more of the outstanding shares of any active covered company in our research universe.
Research Ratings & Price Target Methodology
TPH research ratings and price targets are designed for those with a long-term investment horizon (“investor research”). From time to time, TPH may provide a recommendation with a short-term investment horizon (“trading research”) which may lead to trading research containing different recommendations or ratings that could result in short-term price movements contrary to the recommendation in the firm’s investment research.
Buy – The stock should be purchased aggressively at current prices. The stock has among the best combination of risk/reward and positive company specific catalysts within the sector. Stock is expected to trade higher on an absolute basis and be a top performer relative to peer stocks over the next 12 months.
Hold – Do nothing with the stock at current prices. The stock has average risk/reward and is expected to perform in line with peer stocks over the next 12 months.
Sell – The stock should be sold aggressively at current prices. The stock’s risk/reward is skewed to the downside with possible negative company specific catalysts or excessive valuation. The stock is expected to trade lower on an absolute basis and be among the worst performers relative to peer stocks over the next 12 months.
For detailed rating information, distribution of ratings, price charts and disclosures regarding compensation policy and investment banking revenue, please request a written copy of the disclosures by calling 713-333-2960 (United States).
Investment Rating Distribution
Investment Rating Distribution as of December 31, 2020
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Investment Rating Distribution of the Firm’s Investment Banking Clients for the past 12 months, as of December 31, 2020:
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View Historical Price & Ratings DataView All Tracked Companies
Price Target Methodology
TPH research ratings and price targets are designed for those with a long-term investment horizon (“investor research”). From time to time, TPH may provide a recommendation with a short-term investment horizon (“trading research”) which may lead to trading research containing different recommendations or ratings that could result in short-term price movements contrary to the recommendation in our Firm’s investment research. Price targets are developed using either the stock’s forward price-to-earnings or EV/EBITDA ratio or a build-up of Net Asset Value. There is a risk that the stock will never reach the price target. These risks include market conditions and unforeseen events that may affect the company’s business.
For oilfield service companies, price targets are developed using the stock’s forward price-to-earnings ratio and forward enterprise value-to-EBITDA ratio as the primary valuation metrics. A range of P/E or EV/EBITDA multiples are used depending on the point of the energy cycle and specific business dynamics.
For mid-cycle, these multiples will tend to range from 5-8x EV/EBITDA and 10-15x P/E. Validation of our target is done by examining net asset values, and private market transactions.
For North American E&P companies, we value proved reserves by assessing the net present value of current production. For probable and possible reserves, we attempt basin-by basins analysis of the reserves, with the key variable being the timing of drilling. Our risked 3P NAV consists of a bottom up cash flow model of the current reserves and resources with any appropriate risking as well as adding in a risk adjusted value for exploration prospects. Other businesses such as downstream or gas and power are generally valued on a DCF or multiple basis. We also adjust for items such as G&A, current net debt position and decommissioning liabilities where appropriate.
For integrated oil and gas companies, price targets are primarily based on a target EV/DACF multiple relative to the sector. We use a premium or discount to the sector target EV/DACF multiple to adjust for growth, riskiness of the assets, cash flow profiles and liquidity.
In valuing energy infrastructure companies, we use a variety of valuation methods to derive our price target, including discounted free cash flow (DCF) models, EV/EBITDA multiple valuation, and sum-of-the-parts (SOTP) valuations based on comparable publicly traded companies. DCF discount rates generally range from 7% to 12% depending on our perception of business risk, with more commodity and volume exposed operators toward the higher end. We typically use DCF and EV/EBITDA multiples to value companies across both the midstream and renewable Yieldco space, with free cash flow (FCF) and cash available for distribution (CAFD) the primary cash flow inputs, respectively. We also use SOTP as a secondary methodology for valuing companies with a greater number of business lines, and incorporate a SOTP build-up as a means to triangulate company-specific EV/EBITDA multiples used in our relative valuation approach.
For refining companies, price targets are developed using a sum-of-the-parts (SOTP) approach based typically on forward EV/EBITDA multiples for each business segment. We also adjust for cash and debt, as well as future midstream monetization where applicable. Validation of our target is done by examining net asset values, and private market transactions.
Our primary approach to valuing chemicals companies is to apply an EV/EBITDA multiple over a medium-term profitability outlook. We then adjust for cash, debt, and any other items that may impact the net equity value.
Legal Entities Disclosures
U.S.: Tudor, Pickering, Holt & Co. Securities, LLC is a member of FINRA and SIPC. Canada: Tudor, Pickering, Holt & Co – Canada, ULC is a member of IIROC and CIPF.
Tudor, Pickering, Holt & Co. is the global brand name for Tudor, Pickering, Holt & Co. Securities, LLC (TPHS), Tudor, Pickering, Holt & Co. Securities – Canada, ULC (TPHC), Perella Weinberg Partners LP (PWP), and Perella Weinberg UK Limited (PWUK).Tudor, Pickering, Holt & Co. is the global brand name for Tudor, Pickering, Holt & Co. Securities, LLC (TPHS), Tudor, Pickering, Holt & Co. Securities – Canada, ULC (TPHC), Perella Weinberg Partners LP (PWP), and Perella Weinberg UK Limited (PWUK).
This report is not, and under no circumstances should be construed as, a solicitation to act as securities broker or dealer in any jurisdiction by any person or company that is not legally permitted to carry on the business of a securities broker or dealer in that jurisdiction. To the full extent permitted by law neither Tudor, Pickering, Holt & Co. nor any of its affiliates, nor any other person, accepts any liability whatsoever for any direct, indirect or consequential loss arising from, or in connection with, any use of this report or the information contained herein. No matter contained in this document may be reproduced or copied by any means without the prior written consent of RBC Capital Markets in each instance.
All opinions and estimates contained in this report constitute Tudor, Pickering, Holt & Co.’s judgement as of the date of this report, are subject to change without notice and are provided in good faith but without legal responsibility. Nothing in this report constitutes legal, accounting or tax advice or individually tailored investment advice. This report is not an offer to sell or a solicitation of an offer to buy any securities. Past performance is not a guide to future performance, future returns are not guaranteed, and a loss of original capital may occur.
In accordance with the Canadian Anti-Spam Legislation, TPHC has implied consent from you as a member of the investment community with whom we have already established a relationship through business discussions or dealings, or your email address was made available to TPHC. However, if you are Canadian and wish to stop receiving ANY emails from TPHC (and its affiliated companies), please send an email to UnsubscribeCanada@TPHco.com. Please note that this does not apply if you are an existing client and IIROC rules and regulations require us to continue to send you critical email communications.
This publication is produced by Tudor, Pickering, Holt & Co. Securities, LLC which is regulated in the United States by FINRA. It is to be communicated only to persons of a kind described in Articles 19 and 49 of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005. It must not be further transmitted to any other person without our consent. Any other person should not rely on or act upon the content of this publication.
Persons falling within Article 19 include authorised or exempt investment firms, UK or overseas governments, UK or overseas local authorities or international organisations. Person falling within Article 49 include companies or unincorporated associations with net assets or called-up share capital of £5 million or subsidiary companies of the same that have net assets or called-up share capital of £500,000.
FINRA Rule 2267 requires that member firms provide clients with the FINRA BrokerCheck Hotline Number (800-289-9999), FINRA web site address (www.finra.org) and a notification that a brochure describing BrokerCheck is available from FINRA by contacting FINRA through their web site.
CUSTOMER IDENTIFICATION PROGRAM NOTICE
IMPORTANT INFORMATION ABOUT PROCEDURES FOR OPENING A NEW ACCOUNT
To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.
WHAT DOES THIS REQUIREMENT MEAN TO YOU?
When you open an account, we will ask for your name, address, date of birth and identification number. The identification for a U.S. citizen would be a taxpayer identification number or social security number. For a non-U.S. citizen, the identification number would include a (i) taxpayer identification number, (ii) a passport number along with country of issuance, (iii) alien identification number, or (iv) a government-issued identification document indicating nationality, residence, as well as your photo. We may also ask to see or copy your driver’s license, passport or other identifying documents.
A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement or a trust agreement.
Absent specific order routing instructions from customers, TPHCS transmits orders to various market centers based on a number of factors. Such factors may include the following: the ability of a market center to execute the orders at or superior to the national best bid and offer (NBBO); the ability of a market center to provide price improvement opportunities; the speed of execution; the availability of efficient, automated transaction processing; liquidity enhancement opportunities; the speed of displaying better-priced limit orders; trading characteristics of the particular securities; and the extent to which different markets may be more suitable for different types of orders or different securities.
PAYMENT FOR ORDER-FLOW DISCLOSURE
Tudor, Pickering, Holt & Co. Securities, LLC does not engage in any formal arrangement for the payment for order flow from securities transactions. From time to time, when TPHCS routes orders to a particular market center and is in a position to provide liquidity, a market center may provide TPHCS with a rebate for that order flow.
SEC RULE 13H-1 – LARGE TRADER RULE
The Large Trader Rule requires large traders to register with the SEC and obtain a large trader ID. The Large Trader Rule defines a large trader as any person that:
- Directly or indirectly, including through other persons controlled by such person, exercises investment discretion over one or more accounts and effects transactions for the purchase or sale of any NMS security for or on behalf of such accounts, by or through one or more registered broker-dealers, in an aggregate amount equal to or greater than:
- During a calendar day, either two million shares or shares with a fair market value of $20 million; or
- During a calendar month, either twenty million shares or shares with a fair market value of $200 million; or
- Voluntarily registers as a large trader by filing electronically with the Commission on Form 13H. Please consult with your legal counsel to determine the applicability of the Larger Trader Rule to your activities.
SEC RULE 606 – REPORT DISCLOSURE OF ORDER ROUTING INFORMATION: CLICK HERE
Tudor, Pickering, Holt & Co. has prepared this report disclosure pursuant to U.S. Securities and Exchange Commission Rule 606 requiring all brokerage firms to make publicly available quarterly reports on their order routing practices. The report provides information on the routing of “non-directed orders” – any order that the customer has not specifically instructed to be routed to a particular venue for execution. For these non-directed orders, Tudor, Pickering, Holt & Co. has selected the execution venue on behalf of its customers.
The report is divided into four sections: one for securities listed on the New York Stock exchange, one for securities listed on The Nasdaq Stock Market, one for securities listed on the American Stock Exchange or regional exchanges, and one for exchange-listed options. For each section, this report identifies the venues most often selected by Tudor, Pickering, Holt & Co., sets forth the percentage of various types of orders routed to the venues, and discusses the material aspects of Tudor, Pickering, Holt & Co.’s relationship with the venues.
Tudor, Pickering, Holt & Co. Securities, LLC is a member of the Securities Investor Protection Corporation (SIPC). Please be advised that you may obtain information about SIPC, including the SIPC brochure, by contacting SIPC at www.sipc.org or 202-371-8300.