Merrill Lynch - Policy - Research - Conflicts - 2004

http://www.ml.com/media/43347.pdf


The above document contains the policy announced in 2004 in connection with FSA's (UK) requirements.

Merrill Lynch’s policies and actions resolving conflicts of interest include:

(a) the provision of internal guidance and training on the identification of
possible issues of conflicts of interest as and when they arise;

(b) escalation procedures for ensuring that issues identified are referred to
and considered at the appropriate level within the Firm;

(c) Merrill Lynch’s Control Room monitors potential conflicts of interest
arising in connection with the publication of research in the period
before, during and after Investment Banking transactions;

(d) editorial guidelines and procedures for supervisory and compliance
review of research prior to publication;

(e) the Research Department’s Research Recommendation Committee is
required to approve all investment ratings changes.