Barclays Capital (or "the firm") operates a single Research Department which is committed to providing first-rate and value-added service to both internal and external clients. Barclays Capital is also committed to professionally managing potential conflicts of interest which may arise between its constituent businesses, including potential conflicts between its Research Department and its Investment Banking, Sales and Trading businesses accordingly. Barclays Capital maintains processes, procedures and organisational arrangements to achieve this objective, which are contained in the firm’s Global Research Policy. This policy applies to all publications produced by the firm’s Research Department, including corporate credit, economic, commodities, interest rates, FX and Emerging Market research.

The critical elements of the firm’s Global Research policy include:

• Research does not report directly into a business unit whose commercial interests may conflict with the interests of clients;
• Analyst compensation is derived from the overall profits of the firm, not from specific desks or specific transactions;
• Research publications are only distributed internally at the same time as they are distributed to clients. Research analysts do not provide Trading and Distribution personnel with advance knowledge of the timing and content of forthcoming publications;
• Research analysts are appraised independently from Investment Banking, Trading and Distribution businesses;
• Research analysts do not participate in the marketing of the firm’s investment banking services, including attendance at deal-related pitches and active participation in roadshows;
• Barclays Capital has put in place controls and procedures (including where necessary physical separation) to regulate and, where appropriate, prohibit the flow of information between Research, Trading and Distribution, and Investment Banking;
• Investment Banking personnel and issuers are not permitted to review sections of publications containing recommendations, research summary, price targets or value recommendations, even to verify factual accuracy, prior to publication;

Research publications contain all appropriate prominent disclosures of existing and potential conflicts of interest.

This policy statement complies with the FSA’s New Conduct of Business Sourcebook (COBS) Rules. It is not intended to create third party rights or duties that would not already exist if the policy had not been made available, or to form part of any contract between Barclays Capital and a third party.