It is the policy of Barclays that research reports published by its Global Research Department (“Barclays Research”)1 may not be distributed on a preferential or selective basis. Barclays has adopted and enforces policies and procedures (including information barriers and physical separation, as appropriate) reasonably designed to keep as confidential within the Global Research Department all draft research reports intended for publication until they are made available simultaneously to clients and other parts of the firm by being posted on its password-protected client portal, “Barclays Live.” 2
Draft research reports (other than “pre-deal research reports” in jurisdictions where pre-deal research is permitted) are not provided to, nor reviewed by, the subject company or issuer in advance of publication. However, in certain circumstances, research analysts may submit factual portions of a draft research report to the subject company or issuer for fact-checking purposes.
(1) Method and Timing of Distribution of Research
When a research report is posted on Barclays Live, the firm (i) automatically emails a copy of the report to a distribution list of all of the clients subscribed to receive such research by email and (ii) automatically electronically distributes the report to certain third-party research aggregators, who make it available to entitled clients on password-protected, third-party websites. However, certain categories of research products posted on Barclays Live are not made available to third-party research aggregators.
Clients can manage their research subscriptions on Barclays Live and may opt to receive “bundled” research subscriptions once a day, in the morning or evening, rather than receiving an email as soon as each report is published. Barclays sales personnel or research analysts can also assist clients in managing their research subscriptions.
In certain circumstances, applicable law, regulation, rule, market practice or internal policy may restrict or limit the ability of Barclays to publish research reports on a particular company or issuer (e.g., where the Corporate and Investment Banking division of Barclays has a role in an investment banking transaction involving such company or issuer).
(2) Proprietary Nature of Research
The research reports produced by Barclays are copyright-protected, proprietary products. The reports and the recommendations and opinions contained therein are directed at, and produced for the benefit of Barclays clients. Any unauthorized publication or redistribution of Barclays research reports is prohibited.
1Barclays Research is a part of the Corporate and Investment Banking division of Barclays Bank PLC and its affiliates (collectively and each individually, “Barclays”). Barclays Bank PLC (BBPLC) is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority and is a member of the London Stock Exchange. Barclays Bank PLC is registered in England No. 1026167. Registered Office: 1 Churchill Place, London E14 5HP. The Corporate and Investment banking division of BBPLC undertakes its US securities business in the name of its wholly owned subsidiary Barclays Capital Inc., a FINRA and SIPC member.
2Research reports published by Barclays Equity Research in Japan that involve a material research change (e.g., a change in recommendation or material estimate change) on the subject security or issuer are released simultaneously in both Japanese and English. However, other research reports may be published first in either Japanese or English with a translated version published shortly thereafter.