This document summarises LCF Edmond de Rothschild Securities Limited's ("Edmond de Rothschild's" or "the firm's") policy for identifying and managing conflicts of interest in the production and publication of non-independent research.

This policy applies to all research prepared by persons described in the publication as analysts and published by Edmond de Rothschild for distribution externally.

As a firm authorised by the Financial Services Authority ("FSA"), Edmond de Rothschild is required to act in accordance with the FSA's Principles for Business. Specifically, in relation to the production and distribution of research, the firm undertakes to ensure that it manages any conflicts of interest fairly (Principle 8) and that the research is clear, fair and not misleading (Principle 7).

Research

The FSA's rules (set out in the Conduct of Business Sourcebook - Chapter 12) require firms who hold out their research as being "investment research" to establish and implement a policy for managing the conflicts of interest which may affect the impartiality of their research. Such a management of conflicts policy should address, among other things, the supervision and remuneration of analysts, involvement of analysts in other activities, avoiding inappropriate influence and the means and timing of publication.

The firm has decided, principally because of its analysts' contacts with existing and prospective corporate clients (including participation at pitches for new business and attendance at road shows), that it cannot present its research as being "investment research". It is therefore "non-independent research" and constitutes a "marketing communication".

Non-Independent Research – Disclaimers

As a firm which distributes non-independent research, Edmond de Rothschild is required to identify any such material as a marketing communication and ensure that it contains a clear and prominent statement that it has not been prepared in accordance with legal requirements designed to promote the independence of investment research and is not subject to any prohibition on dealing ahead.

Although the firm's research does not meet the FSA's definition of independent investment research, the firm has put in place controls and procedures to manage conflicts of interest which may arise in the production and distribution of its non-independent research materials. These policies are summarised below.

Summary of Conflicts Management Policies

The firm has implemented controls and procedures to manage conflicts of interest in relation to the production and publication of its non-independent research. The following are the key controls and procedures:

(a) Organisation of the firm

The firm is divided into departments, with the Corporate Finance and Broking departments being behind a Chinese wall separate from other departments. The Chinese wall includes physical and other barriers (e.g. Corporate Finance computer systems not accessible by Research, Sales or Trading). There are controls over analysts being taken over the wall and on the use and disclosure of confidential and price sensitive information by those persons over the wall.

The firm publishes research in support of offerings of securities where it is acting for the issuer. Subject to any constraints required by maintaining an effective Chinese wall in respect of any price-sensitive matter, an analyst writes that research and may be involved in the preparation of other issuer marketing. That analyst may also participate in roadshows for an offering, or in another capacity such as advising on allocation or pricing. However, the analyst does not have access to the information held within the Corporate Finance department, and is instructed to present research which fully and fairly reflects their view of the issuer and/or security.

(b) Editing and reviewing research

Edmond de Rothschild does not have a dedicated editorial function. However, all research material is subject to peer review and vetting by the Head of Compliance prior to distribution, to ensure the research adheres to the policies in this document.

Prior to the distribution of a piece of research, the Corporate Finance department and/or the company which is the subject of the research may be shown the contents and permitted to comment on any factual errors. They are not permitted to alter the substance of the opinion or recommendation of that research. A record is kept of any subject company comments.

(c) Supervision and remuneration of analysts

The Board of Directors has overall control of the firm, including the Research department. Analysts report to the Head of Research, who in turn reports to the Board of Directors. The Head of Research signs off a formal research report along with, as appropriate, Compliance.

Analysts are remunerated by a combination of salary and discretionary bonus, which is decided by the Remuneration Committee and is based on a formal appraisal process regarding the analyst’s performance and the overall profitability of the firm (including profits from corporate finance activity).

The remuneration of the firm's analysts is not based on expressing a specific view or recommendation about an issuer, security or industry.

(d) Inducements in connection with research

Analysts are prohibited from accepting any gifts or inducements in return for writing a piece of research on a particular issuer. Attempts by the subject company or another person to put pressure on an analyst to produce favourable research are subject to disclosure to Compliance and to the firm's internal procedures.

(e) Personal account dealing

Personal account dealing restrictions apply to all staff. Staff are required to obtain prior Compliance approval before personal account dealing.

Analysts are prohibited from dealing in investments (or related investments) on which they produce research.

(f) Manner and timing of distribution of research

Printed research is only distributed through the firm's usual channels (i.e. by email, post or on the firm's website.) To prevent an allegation of dealing ahead of the publication of research material, Edmond de Rothschild's analysts distribute research simultaneously to the firm's investment clients and the institutional broking department, and would not intentionally distribute to one investment client before any other. However, it may not always be possible to ensure that all clients receive that piece of research simultaneously.

Prior to the intention to publish research, sales may be consulted about likely investor interest in the prospective research. The analyst is prohibited from divulging either the likely timing or content of the research.

Once the intention to write research has been formed, the analyst must not communicate with trading, sales or selectively with investment clients prior to the publication or distribution of research to the firm's clients.

Traders are prohibited from effecting own account transactions in advance of research publication or distribution except for market making in the normal course of business and in good faith or for unsolicited client orders.

Analysts are prohibited from preparing research papers or analysis which are intended firstly for internal use for the firm's own advantage, and later for publication to clients.

The firm restricts the publication and distribution of research around the time of both primary and secondary securities offerings through the operation of quiet periods; there are also restrictions designed to maintain the integrity of pre-flotation research published by the firm in respect of IPOs.