REGULATORY DISCLOSURES

ANCILLARY SERVICES

Spread Research’s two ancillary services are Credit News flow and Investment Recommendations:

– Credit News flow: Spread Research’s analysts comment key credit news related to the companies they cover. This takes the form of a daily alert email which includes the summary of the news and a comment which analyses the credit impact. This is available on our website.

– Investment Recommendations: We provide Investment Recommendations on Corporate bond new issues based on our credit opinion & our independent credit spread & re-offer yield views. We provide secondary market Trade Ideas via our EHY Corporate Bond Long-Only Model Portfolio.

COMPENSATION ARRANGEMENTS

Spread Research acting as an Independent Research Provider is paid by investors that subscribed to our independent credit research & unsolicited ratings, investment recommendations and news flow services.

Solicited ratings are paid by the rated entity or related third parties. Unsolicited ratings are not paid by the rated entity. A rating cannot be paid by both the rated entity and bond investors.

As defined in the code of conduct and in order to eliminate any conflict of interests, the same rating cannot be paid by both investors and issuers/arrangers.

The compensation of the rating analysts or the compensation of the compliance officer, either fixed or variable are not linked the business performance and are arranged so as to ensure the independence of their judgment.

CODE OF CONDUCT

You will find enclosed the code of conduct of our company:

SPREAD RESEARCH – CODE OF CONDUCT

CONFLICTS OF INTERESTS

You will find enclosed the list of potential conflict of interests of our company:

SPREAD RESEARCH – CONFLICT OF INTERESTS

TRANSPARENCY REPORT