Policy on independence
General

All Investment research issued by New Street Research LLP (“New Street”) is independent, impartial and objective.

New Street does not conduct any investment business with or for its clients (other than the provision of research) or on its own account. New Street staff have no responsibilities which could conflict with the interests of our investment research clients. New Street does not carry out any corporate finance business; does not sell or trade securities; and has no involvement in raising capital for corporate clients.

New Street has no other regulated or unregulated business activities which conflict with its provision of independent research.

New Street’s research is not intended for Private Customers.

All of New Street’s investment analysts are supervised by senior partners of the firm.

The remuneration structure for New Street’s analysts is not linked in any way to dealing or other activities which our customers carry out as a result of the independent research provided by the firm.

Our analysts are not permitted to be involved in any activities which could be seen as conflicting with our provision of investment research to our clients.  No inducements offered by issuers, or others with a material interest in the subject matter of investment research, may be accepted by our investment analysts or senior partners of the firm.

No employee of New Street may carry out any personal account dealing which could create a conflict of interest which might affect the impartiality of New Street’s investment research.  Any proposed personal account dealing by employees is subject to pre-approval by a senior partner of New Street and no dealing which could create a conflict of interest between the employees of New Street and our customers is permitted.  In addition, a prohibited list of securities is maintained.  Note that New Street itself does not hold securities on its own account. All outside business activities of employees are subject to prior approval by a senior partner of the firm.

Our Research

The timing and manner of publication and distribution of investment research and of the communication of its substance must be approved in advance by a senior partner of New Street. Before being issued, all research documents must be approved and signed-off by a senior analyst. No one outside New Street may comment on draft investment research before publication, other than, where necessary, to verify factual information.

Certain disclaimers may be included in our research where appropriate, for example for legal reasons. New Street's policy and procedures require investment research to be distributed in an appropriate manner.

Our investment research is published and distributed either in hard copy or on line. No employee may communicate the substance of any investment research, except in accordance with our policy of independence.

Sponsored Research

From time-to-time, New Street may agree with a specific issuer that the cost of a  research report will be paid for by the issuer to whom the report relates.  Where New Street publishes such sponsored research, it will be clearly and prominently identified as such.  In all respects, such a report will be prepared according to New Street’s normal, rigorous standards of impartiality and objectivity.  Other than for verification of factual information, the sponsoring issuer will not be permitted to comment on the research prior to publication.

The purpose of accepting such sponsorship is primarily to allow New Street to provide timely research on issuers falling outside the normal scope of our research coverage, for example smaller firms or those outside our normal geographical coverage.

Any questions relating to this policy should be addressed to John McEwing.

7 January 2008