Research Conflict Management Policy Statement

Barclays Bank PLC and its affiliates (collectively and each individually “Barclays” or "the firm") operates a Global Research Department which is committed to providing first-rate and value-added service to both internal and external clients.

Barclays 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, Trading and Distribution businesses accordingly. Barclays maintains processes, procedures and organisational arrangements to achieve this objective, which are contained in the firm’s Global Research Policy, Equity Research Standard, FICC Research Standard as well as in the Research Department’s business procedures (together, “Research Policies and Procedures”).

The Research Policies and Procedures apply to all publications produced by the firm’s Research Department, including equity, corporate credit, economic, asset allocation, quantitative portfolio strategy, interest rates, FX, securitised products, commodities, and Emerging Market research.

The critical elements of the firm’s Research Policies and Procedures include:

  • The Research Department does not report directly into any business unit whose commercial interests may conflict with the interests of the firm’s investing clients;
  • Research analyst compensation is derived, in part, from the overall profits of the firm, not from revenues from Investment Banking or specific trading desks or specific investment banking or trading transactions;
  • Research reports are only distributed internally at the same time as they are distributed to clients. Research analysts do not provide Investment Banking, Trading, Distribution or other non-Research personnel (other than Legal and Compliance personnel) with advance knowledge of the timing and content of forthcoming research reports;
  • Performance evaluations of research analysts are conducted by Research Management, and input from other business (such as from the Investment Banking, Trading and Distribution businesses) is appropriately prohibited or limited in accordance with applicable regulatory requirements;
  • Research analysts do not participate in the solicitation of investment banking business, including attendance at pitch meetings to solicit investment banking business;
  • Research analysts do not participate in the marketing of the firm’s investment banking transactions, including active participation in deal-related roadshows;
  • Barclays has implemented and enforces controls and procedures (including appropriate physical separation) to regulate and, where appropriate, prohibit the flow of information between Research and non-research personnel, including Investment Banking, Trading and Distribution;
  • Investment Banking personnel and issuers are not permitted to review non-public information containing in unpublished research reports, including sections containing non-public information about unpublished recommendations, ratings, price targets, estimates or valuation analysis, or summaries of investment conclusions, even to verify factual accuracy; and
  • Research reports must clearly and prominently disclose actual and potential conflicts of interest in accordance with all applicable rules and regulations.

  • This policy statement 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 and a third party.