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Hardman & Co’s research is paid for by the companies, legal entities and issuers about which we write and, as such, falls within the scope of ‘acceptable minor non-monetary benefits’, as defined in the Markets in Financial Instruments Directive.

The FCA Handbook (COBS 2.3A.19) states: ‘An acceptable non-monetary benefit is one which:[…] (5) consists of: […] (b) written material from a third party that is commissioned and paid for by a corporate issuer or potential issuer to promote a new issuance by the company, or where the third party firm is contractually engaged and paid by the issuer to produce such material on an ongoing basis, provided that the relationship is clearly disclosed in the material and that the material is made available at the same time to any firms wishing to receive it, or to the general public.

The fact that Hardman & Co is commissioned to write the research is disclosed in the disclaimer, and the research is widely available.

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Effective June 2024.