Conflict Management Policy

Statement of Policy

The following rule and subsequent policy is to ensure that all investment research material is defined as objective and impartial in its content unless stated otherwise. This publication is produced and distributed in accordance with 'COBS 12.2 - Investment Research' of the FCA Handbook. Should you require further details on this rule please see www.fca.gov.uk (this will take you out of the tullett prebon domain).

The Policy

All published research that is externally distributed will be objective and impartial in its content.

Any information or facts which would materially affect the research known to the author at the time that would render the content to be of a non-objective or biased nature will be disregarded when producing any research.

All authors are directly employed by and represent at all times either Tullett Prebon (Europe) Limited and Tullett Prebon (Securities) Limited, both of which are authorised and regulated by The Financial Conduct Authority for the conduct of investment business in the UK, including the provision of advice on investments.

All authors are obliged to abide by this policy at all times. Any Tullett Prebon Group Ltd employee giving research and advice, either written or orally, will do so in the best interests of all Tullett Prebon Group Ltd clients with complete impartiality. In conjunction with this Conflict Management Policy there currently exists an Independence Policy to which all authors and brokers adhere so as to maintain clients’ interests at all times and which they are obliged to be bound by prior to any research being produced.

Any publication produced which does not adhere to the conflict management policy will be clearly stated as such to the recipient at the time of presentation.

Should you require further information on this policy and what it means for you then please contact the Tullett Prebon Group Ltd Compliance Department on +44 (0)20 7200 7912.

Please note that this is intended for wholesale professional customers only and Tullett Prebon Group Ltd does not deal for, or advise upon investments for private clients or individuals.