Brandon Hill Capital

Brandon Hill Capital Limited aims to maintain research coverage on all companies to which the firm acts as a corporate broker or financial adviser in the UK. Analysts are expected to apply the same standards and approach to all companies regardless of any corporate relationship. To ensure equality of treatment, any new piece of research or significant change to an estimate or recommendation must be disseminated to clients and the sales team simultaneously, and clients allowed a reasonable time to react. A trader or salesperson who for any reason becomes aware of any such publication or change before it has been disseminated to the market is prohibited from communicating the substance of the publication or change to any person outside Brandon Hill Capital Limited, until dissemination to clients has taken place. Research is disseminated to clients through established distribution channels described above. On occasion the group of recipients will be tailored in line with Brandon Hill Capital Limited's perception of the class of those who will be interested in its contents, or for reasons related to securities laws in the jurisdiction of the recipient, so that not all clients will receive it. When research is disseminated in hard copy only, distribution is sometimes staggered so that some clients will receive it before others; however this typically only applies where the securities to which the research relates are not yet publicly traded, and therefore Brandon Hill Capital Limited does not expect any client to be prejudiced. The majority of the business executed by Brandon Hill Capital Limited's broking departments is client driven. However, the firm does make a market in some UK investment trusts and some UK smaller companies. The firm may also take proprietary positions to execute client business or in the course of a distribution of securities on behalf of a corporate issuer or in the secondary market. Procedures are in place to ensure that analysts do not have knowledge of any proprietary position in order to prevent this knowledge from influencing their views. Equally, market makers are prohibited from having advance knowledge of the timing or content of research publication in order to prevent them taking advantage of this information ahead of the firm's clients.