Guidance

1. Investment Research is seen as a significant potential source of conflicts of interest within an Authorised Person and therefore an Authorised Person preparing or publishing investment research is expected to have adequate procedures, systems and controls to manage effectively any conflicts that arise.
2. An Authorised Person that prepares and publishes Investment Research must have adequate procedures and controls to ensure:
(i) the effective supervision and management of Investment Analysts;
(ii) that the actual or potential conflicts of interest are proactively managed in accordance with Rule 3.5;
(iii) that the Investment Research issued to Clients is impartial; and
(iv) that the Investment Research contains the disclosures described under Rules 6.4.2 and 6.4.4.
3. An Authorised Person's procedures, controls and internal arrangements, which may include Information Barriers, should limit the extent of Investment Analysts' participation in Corporate Finance Business and sales and trading activities, and ensure remuneration structures do not affect their independence.