Summary of Global Conflicts of Interest Policy - Barclays Capital

Barclays Capital
Summary of Global Conflicts of
Interest Policy
1 November 2007

Introduction
As an institution that offers a wide variety of products and services to a broad and diverse client range, Barclays Capital
can, from time to time, find itself in a situation where the interests of one client may be in competition with those of
another, or indeed where the interests of a particular client may be in competition with the interests of Barclays Capital.
The Global Conflicts of Interest Policy provides a clear guide on identifying and resolving those conflicts.
A potential conflict of interest can arise where the opportunity exists to put the interests of one person / entity before
the interests of another in circumstances where to do so would result in a failure to take into proper consideration the
interests of that other person.
The existence of a potential conflict of interest does not, in and of itself, constitute wrongdoing, rather it would be a
failure to manage such potential conflict appropriately that would constitute improper behaviour.
Purpose
The purpose of this document is to provide clients with a summary of the standards applied by Barclays Capital to (i)
minimise those sets of circumstances in which a potential conflict of interest might arise, (ii) identify any potential
conflicts (real or perceived) that do arise, and (iii) where a potential conflict of interest is identified, ensure that any
competing interests are appropriately addressed.
Section 1: Application
Territorial Scope
Product Scope
Exclusions
The application of this policy applies to all of Barclays Capital’s employees worldwide.
This policy is applicable to all product areas and services.
None.
Section 2: Minimising the occurrence of conflicts
Supervision,
Reporting Lines and
Remuneration
Controls concerning
the disclosure of
information
Barclays Capital ensures due consideration of the potential for conflicts of interest is given with
respect to all decisions relating to supervision, reporting lines and remuneration. Barclays
Capital actively takes steps to ensure that its individuals, departments and divisions are neither
improperly incentivized nor are they supervised by individuals who themselves are improperly
incentivized.
Barclays Capital imposes strict controls concerning the dissemination of sensitive information
through its Global Confidential Information and Chinese Walls Policy, which sets out specific
policies and procedures.

Section 3: Identification of Conflicts of Interest
Application
Investment
Research
Inducements
Barclays Capital has put in place protocols to ensure that it is able to identify potential conflicts of
interest at both the macro-level (e.g., committee approval for new lines of business) and microlevel
(e.g., Control Room functions). Barclays Capital also has in operation a wide range of
monitoring tools in order to detect any activity that may constitute a potential conflict of interest.
Barclays Capital has in place a separate policy regarding Research. A summary of this policy is
available on the Barclays Capital internet site.
Barclays Capital has put in place protocols to ensure that no improper inducements are given or
received and proper inducements are disclosed appropriately.
Section 4: Management of Potential Conflicts of Interest
Application
Disclosure
Barclays Capital has put in place certain transaction-specific measures (e.g., transaction-specific
Chinese walls and review committees), employee-specific measures (e.g., Personal Account
Dealing Policy), surveillance measures (e.g., monitoring of our Restricted List) and training
initiatives to manage potential conflicts of interest and to ensure fair treatment of our clients.
Barclays Capital will disclose the existence of a conflict of interest if transaction-specific measures
are inadequate to manage the conflict.