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Measures and procedures with respect to investment research

Measures and procedures for handling conflicts of interests with respect to investment research

FFBH applies measures and procedures for handling conflicts of interest with respect to financial analysts participating in the preparation of investment research which is designated for dissemination or may subsequently be disseminated to the public or among its clients, and with respect to others working under a contract for FFBH, whose responsibilities or business interests may come into conflict with the interests of the persons to whom the investment research is provided.

FFBH ensures compliance with the following requirements:

1. the financial analyst, and the others working under a contract for FFBH, may not conclude personal transactions or conclude transactions for the account of another person, FFBH included, in securities to which the investment research relates, or in any related financial instruments, with the knowledge of the likely timing or content of the investment research. This applies only when the investment research is not available to clients or the public and cannot readily be inferred from information that is available to the public or the clients. The prohibition shall be valid until the recipients of the investment research have had a reasonable opportunity to act on it;

2. in circumstances not covered by item 1, the financial analyst and the other persons, who work under a contract for FFBH and are involved in the production of investment research, must not undertake personal transactions in securities to which the investment research relates, or in any related financial instruments, contrary to the current recommendations, except in exceptional circumstances and with the prior approval of FFBH’s legal or internal control department;

3. FFBH, financial analysts and others working under a contract for FFBH involved in the production of the research, must not receive remunerations, commissions or non-pecuniary benefits from persons with a material interest in relation to the subject of the investment research and its recommendation;

4. FFBH, financial analysts and others working under a contract for FFBH involved in the production of the investment research, must not promise issuers favorable research coverage;

5. issuers, FFBH employees (except the financial analyst) nor any other person should be permitted to review the investment research before its dissemination, even for the purpose of verifying the accuracy of the factual statements made in the research, or for any other purpose other than verifying compliance with FFBH’s legal obligations, if the research includes a recommendation or a target price.

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