(a) Analysts must not trade in securities or related derivatives ahead of publishing research on the issuer of these securities;

(b) Analysts must not trade in securities or related derivatives of any issuer that they review in a manner contrary to their existing recommendations except in special circumstances subject to pre-approval by compliance or legal personnel;

(c) Analysts must not accept inducements by issuers or others with a material interest in the subject matter of investment research; and

(d) Investment firms must not promise issuers favorable research coverage, specific ratings or specific target prices in return for a future or continued business relationship, service or investment.