Shares - - CONTENTS -

Shares pub­lishes in­for­ma­tion and ideas which are of in­ter­est to in­vestors. It does not pro­vide ad­vice in re­la­tion to in­vest­ments or any other fi­nan­cial mat­ters. Com­ments pub­lished in Shares must not be re­lied upon by read­ers when they make their in­vest­ment de­ci­sions. In­vestors who re­quire ad­vice should con­sult a prop­erly qual­i­fied in­de­pen­dent ad­viser. Shares, its staff and AJ Bell Me­dia Lim­ited do not, un­der any cir­cum­stances, ac­cept li­a­bil­ity for losses suf­fered by read­ers as a re­sult of their in­vest­ment de­ci­sions.

Mem­bers of staff of Shares may hold shares in com­pa­nies men­tioned in the mag­a­zine. This could cre­ate a con­flict of in­ter­ests. Where such a con­flict ex­ists it will be dis­closed. Shares ad­heres to a strict code of con­duct for re­porters, as set out be­low.

1. In keep­ing with the ex­ist­ing prac­tice, re­porters who in­tend to write about any se­cu­ri­ties, de­riv­a­tives or po­si­tions with spread bet­ting or­gan­i­sa­tions that they have an in­ter­est in should first clear their writ­ing with the ed­i­tor. If the ed­i­tor agrees that the re­porter can write about the in­ter­est, it should be dis­closed to In­dex of com­pa­nies and funds in this is­sue read­ers at the end of the story. Hold­ings by third par­ties in­clud­ing fam­i­lies, trusts, self-select pen­sion funds, self select ISAs and PEPs and nom­i­nee ac­counts are in­cluded in such in­ter­ests.

2. Re­porters will in­form the ed­i­tor on any oc­ca­sion that they trans­act shares, de­riv­a­tives or spread bet­ting po­si­tions. This will over­come sit­u­a­tions when the in­ter­ests they are con­sid­er­ing might con­flict with re­ports by other writ­ers in the mag­a­zine. This no­ti­fi­ca­tion should be con­firmed by e-mail.

3. Re­porters are re­quired to hold a full per­sonal in­ter­est reg­is­ter. The where­abouts of this reg­is­ter should be re­vealed to the ed­i­tor.

4. A re­porter should not have made a trans­ac­tion of shares, de­riv­a­tives or spread bet­ting po­si­tions for seven work­ing days be­fore the pub­li­ca­tion of an ar­ti­cle that men­tions such in­ter­est. Re­porters who have an in­ter­est in a com­pany they have writ­ten about should not trans­act the shares within seven work­ing days af­ter the on-sale date of the mag­a­zine.

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