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Information on our conflicts of interest policy

Version: March 2019 For information about our investment bank entities, visit www.ubs.com/ibterms

Information on our conflicts of interest policy

1 Why do we have a Conflicts of Interest policy? (ii) the interests of UBS or its employees are different to (a) UBS operates in many jurisdictions all over the globe. We are those of the client active in many markets in all kinds of transactions. We are (iii) there is the potential for a financial or other incentive engaged in a wide range of financial services including to favour the interests of one client or group of clients corporate and investment banking, securities trading, asset over another management, wealth management and retail banking. We (iv) monetary or non-monetary benefits have been act simultaneously for many clients in many different received from a third party in relation to a service capacities. We also act on our own behalf. As a result, supplied to the client other than standard commissions unavoidably, the various interests we represent will or fees sometimes conflict. (v) UBS or that person carries on the same business as the (b) UBS principles and practices that define our ethical client standards and the way we do business are set out in our Code of Conduct and Ethics (attach link). This states that 5 How does UBS manage conflicts of interest? "We put our clients' best interests before our own – and (a) UBS will seek to manage the conflict of interest through the UBS's interests before our personal interests. And we never following measures or combinations of measure (this list is let UBS's or our personal interests influence our advice to a not exhaustive): client, or our dealings with them". We have policies and procedures in place to address and manage conflicts of (i) Setting up electronic and/or physical barriers including interest as they arise. This document summarises the internal system access restrictions to prevent the flow of conflict of interest policy maintained by UBS in respect of information between conflicting business activities regulated activities carried out within the European (ii) Appropriate governance, transparency and oversight Economic Area. of compensation of UBS or its employees to avoid incentivising behaviours that conflict with our duty to 2 Which employees are in scope of this policy? act in the best interest of our clients (a) The UBS Conflicts of Interest Policy applies to all UBS staff, (iii) Establishing supervision and monitoring procedures to whether permanent or temporary, anyone else providing ensure employees are complying with our policies services to UBS and to tied agents or other appointed representatives of UBS. (iv) Controlling the type of tasks employees are allowed where types of duties could conflict with each other 3 What are the guiding principles followed by UBS? (v) Oversight and approval committees, independent from (a) UBS is committed to treating its clients fairly and with directly involved UBS employees integrity across all its business activities (vi) Controls to restrict and monitor personal investment (b) UBS is committed to complying with all applicable legal and and external business activities of UBS employees to regulatory requirements relating to the proper identification prevent conflicts of interest arising against the interest and management of conflicts of interest of clients (c) UBS is committed to maintaining and operating effective (vii) Providing general or specific disclosures of the conflict organizational and administrative arrangements to identify of interest and manage actual or potential conflicts of interest (b) If it is considered that appropriate measures cannot be put (d) UBS recognizes that the most important factor allowing it in place to manage the conflict UBS would either decline to successfully to manage conflicts of interest is a culture of act for a client(s) if their interests (or another client(s) integrity. interests) may be materially harmed by the potential conflict (e) UBS recognizes that remuneration structures must support of interest or obtain the consent of such client(s) . conflict management and independence 6 What training do employees receive in relation to (f) UBS expects its employees to apply the same standards of conflicts of interest? skill, due care and diligence in its dealings with other UBS entities or divisions as they would if dealing with a third (a) All UBS employees receive group wide web based training party on how to recognize and manage conflicts of interest. This is complemented by specialized face to face training for 4 What factors are considered when identifying conflicts certain business activities. of interest? 7 How often is the Conflicts of Interest policy reviewed? (a) When identifying the types of conflict of interest that may (a) We monitor the effectivesness of the prodecures for arise in the course of providing a service which may entail a conflcits of interest on ana on-going basis and will review material risk of damage to the interests of client or the the policy at least once a year. We will update and republish integrity of the financial market, UBS and its employees take this document whenever material changes are required. account of whether: (i) UBS or its employees is likely to make a financial gain or avoid a loss, at the expense of the client

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