Stockbrokers. Supplemental Terms. International Trader

Transcription

1 Stockbrokers Supplemental Terms International Trader

2 Supplemental Terms This document is supplemental to the Barclays Terms and shall be referred to as the Supplemental Terms. The purpose of this document is to describe which terms apply to our International Trader services. This document along with, the Barclays Terms (the Barclays Terms ), form part of the Agreement between us as defined in the Barclays Terms. If there is any conflict between the Supplemental Terms and the Barclays Terms, these Supplemental Terms will prevail. If words beginning with a capital are not defined in these Supplemental Terms, they shall have the same definition as in the Barclays Terms. 2 The following sections of the Barclays Terms are relevant to the services provided under the Agreement: Section A, Section B, Section D, Section F, Section G, Section H, Schedule 1, Schedule 2, and Schedule 3. Please refer to the Barclays Terms Section A Paragraph 18 for details of your classification under the FCA Rules 1. Definitions (Additional to Section H of the Barclays Terms) Corporate Event has the meaning given in Paragraph 9.3; Investments means international equities which you can trade by using the Services International Trader Account means the account from which, in relation to the purchase of Investments, the purchase monies will be debited and into which (i) in relation to the sale of Investments, the sale proceeds, and (ii) any dividends, interest and other payments received for you; will be credited; International Trader Platform means the electronic trading platform, accessed via the Website, through which you can trade in Investments in accordance with these terms and conditions; International Trader User ID means your individual security code which will give you access to the International Trader Platform and your International Trader Account; MarketMaster Account means your Barclays Stockbrokers account used to hold your cash; MarketMaster User ID means your individual security code which will give you access to your MarketMaster Account; Market means the investment exchanges on which you can deal via the International Trader Platform from time to time; Nominated Account means the bank or building society account in your name (including a joint account which you hold with somebody else) specified by you in your Application Form or such other account as may be nominated by you from time to time; Normal Market Hours means, in relation to an applicable Market, the days on which and the hours between which such Market is usually open for trading. Details of the Normal Market Hours of each Market are available on our Website; Platform Operator means the third-party provider of the International Trader Platform; Services has the meaning set out in clause 2.1; Settlement Date means, in relation to a sale of Investments, the date that the proceeds of sale are credited to the International Trader Account, and, in relation to the purchase of Investments, the date that the purchase monies are debited from the International Trader Account; we, us, means Barclays Stockbrokers or any other member of the Barclays Group acting on your behalf pursuant to the Services to be performed under these Supplemental Terms;

3 Website means our website at BarclaysStockbrokers.co.uk and any other websites we provide in connection with the Services from time to time. 2. The Services 2.1 These Supplemental Terms set out the terms and conditions under which we will provide an executiononly dealing service (as described in Section B Part 4 Paragraph 12 of the Barclays Terms) through the International Trader Platform. The International Trader Platform will provide access to Investments traded on the Markets. We will refer to the services described in this clause 2.1 as the Services. 2.2 The Platform Operator is the owner and operator of the International Trader Platform. However, we will retain ultimate responsibility and are accountable to you for your International Trader Account and any transactions you carry out on the International Trader Platform. 2.3 We will arrange orders on your behalf as your agent and not as principal for our own account. We will, acting as your agent, receive and transmit your instructions to the Platform Operator for execution. 2.4 In accordance with clauses 2.2 and 2.3, you hereby appoint us, as your agent, with the sole right to: (i) enforce your rights under any such transaction with the Platform Operator on your behalf; and (ii) to discharge your obligations to the Platform Operator in respect of such transactions on your behalf. Accordingly, you shall have no independent right to, and shall not, seek recourse directly to, or redress directly from, the Platform Operator in respect of any such transaction. You shall address any claim or complaint in respect of any such transaction to us in accordance with clause As your agent, we will owe you the duty of best execution as described in Section B Part 4 of the Barclays Terms and Schedule A of these Supplemental Terms, which shall replace any Execution Policy referred to under the Barclays Terms. 2.6 The Services are provided by Barclays Stockbrokers. We are authorised and regulated by the FCA. You can find us on the FCA Register by searching for our registration number: Our Website is intended for use by UK residents only. The Services are not intended for use or distribution in countries where it would be illegal for us to provide such Services. We are unable to offer our Services in these countries. If you access the Website from outside the UK, it is your responsibility to inform yourself of and observe any applicable local laws. 2.8 The Services will only be provided to you once you have completed all documentation relevant to the International Trader Account. It is your responsibility to ensure that you comply at all times with all applicable laws and regulations when using your International Trader Account and the Services. 3 Opening Your Account Eligibility 3.1 The Services are only available to residents of the UK that are aged 18 or over. If you relocate to another country, we may not be able to provide you with the Services; accordingly, you should notify us promptly of any change to your circumstances. 3.2 Before you can use the Services, you will need to open a MarketMaster Account. Your access to a MarketMaster Account is subject to separate terms and conditions and a separate application form. You will need to complete and return the MarketMaster Account Application Form for our approval before we will consider your application for International Trader. If you are an existing MarketMaster Account holder we may still need to contact you for additional information before completing your International Trader Account application. 3.3 In order to be eligible to deal in US securities, you must complete and return the appropriate US tax documentation. You must notify us promptly if there is any change in any of the information that you have given to us in such tax documentation. 3.4 You can apply for the Services by completing an online application. 3

4 Getting Started 3.5 We will open an International Trader Account for you once your application has been accepted. We will send you a communication containing your International Trader User ID and the link to the International Trader Platform. You will need your International Trader User ID in order to access your International Trader Account and the International Trader Platform and to give us dealing instructions either online via the International Trader Platform or by telephone. 4. Giving Instructions (Additional to Paragraph 2, 3 and 4 of the Barclays Terms) 4.1 You can give us dealing instructions for the Services: (a) by telephone (to telephone number ); or (b) through the International Trader Platform. 4.2 We will not accept your dealing instructions in writing, by , fax or any form of communication via the Internet other than through the International Trader Platform. 4.3 When giving us dealing instructions (either by telephone or via the International Trader Platform), we will ask you to identify yourself using your International Trader User ID or MarketMaster User ID and any other Security Information that we request. We may refuse to act on your instructions if you do not provide the correct User ID or Security Information. 4.4 Our Website specifies the times when we will accept instructions to deal via the International Trader Platform. Usually we will accept instructions by telephone on any Working Day between the hours of 7.30am and 8.30pm. Instructions received by us on any day which is not a Working Day or outside of our usual dealing hours will be treated as having arrived on the next Working Day. 4.5 Subject to paragraph 8.7, where we receive instructions to deal outside Normal Market Hours, we will act upon such instructions as soon as practicable when the relevant Market is open for trading. 4.6 Dealing instructions placed by you on the International Trader Platform will be executed with the Platform Operator in accordance with paragraph 2.3. The Platform Operator will enter into corresponding transactions with third parties in order to fulfil the order. 4.7 The Platform Operator may refuse to accept any order or instruction for your account. For example, the Platform Operator may refuse to fulfil an order in the event that the Platform Operator considers (i) that the International Trader Platform is being used for an improper purpose, or (ii) that acting upon the instruction will result in a breach of legal or regulatory requirements, or (iii) that emergency or exceptional market conditions exist (please note that this is not an exhaustive list of circumstances). The Platform Operator will advise us of its decision and the reason for the decision unless the Platform Operator is prevented from doing so due to any legal or regulatory constraints. Where we receive such notification from the Platform Operator, we will communicate it to you as soon as practicable and, in accordance with clause 2.2, above we will be responsible for such acts of the Platform Operator. 4.8 In certain circumstances, we or the Platform Operator may cancel an order following your receipt of confirmation from the International Trader Platform that the order has been accepted. This could occur, for example, because the transaction has been rejected or cancelled by any Market on which the order was to be executed, or because the Platform Operator is otherwise unable to execute the transaction with third parties in order to fulfil the order. In such circumstances, we will notify you; the original confirmation of your order will be deemed to be ineffective; and we will return to you any monies representing amounts to be invested that may have been deducted from your International Trader Account in connection with such order. 4.9 We may suspend or permanently withdraw your access to the Services in the event that we, or the Platform Operator, considers that your use of the International Trader Platform is in breach of the Agreement, or for an improper purpose such as (for example) any behaviour which: (a) might be considered to be abusive in accordance with 4

5 legal or regulatory requirements; (b) involves the adoption of trading strategies aimed at exploiting misquotations; or (c) we consider to amount to bad faith or an attempt to abuse information or facilities available on the International Trader Platform. In such circumstances, we may take such additional action as we reasonably consider to be appropriate to address any such misuse, which may include (among other steps), the cancellation of any outstanding trade or the deduction of any cash or securities held by us or our delegates on your behalf that we consider to represent the proceeds or profits of any transaction that has been conducted via the International Trader Platform for an improper purpose We may temporarily suspend the Services where this is reasonably necessary for routine system maintenance, adverse market conditions or other circumstances beyond our control. We may also suspend the Services where the Platform Operator suspends or otherwise restricts the operation of the International Trader Platform. In such circumstances we may, or may authorise the Platform Operator to close out or suspend any currently open transactions that we have executed on your behalf. We will try to inform you in advance of any suspension of the Services or other action taken pursuant to this clause but it may not be possible to do so. 5. Other Communications (Additional to Paragraph 4 of the Barclays Terms) 5.1 If you want to give us a dealing instruction, please follow the procedure set out in clause 4 above. If you need to contact us for any other reason, please do so by post, telephone, fax or at: Barclays, Tay House, 300 Bath Street Glasgow G2 4LH Telephone: * or local number * Fax: stockbrokers@barclays.com, or such other contact details as we notify to you in writing from time to time. 5.2 Given the nature of the Services, we may communicate with you by posting information on our Website or by sending electronic messages to you via the International Trader Platform. If an electronic message has been sent to you via the International Trader Platform, you will be notified of this when you access the International Trader Platform. It is your responsibility to check the Website and the International Trader Platform for any communications or updates relating to the Services. We will treat electronic messages as having been received and read by you once you have accepted the message prompt notifying you of the message. 6. Your Account (Additional to Section D Part 2 of the Barclays Terms) 6.1 In order to fund your trading activity, you will need to use either your MarketMaster Account or your Nominated Account. You can instruct us to move funds from your MarketMaster Account to your International Trader Account by telephone. Funds transferred from your MarketMaster Account before 4.00pm will usually be available for trading on the same day. 6.2 Unless you request otherwise your International Trader Account will be denominated in Sterling. If you wish to have a sub-account denominated in US Dollar or Euro please contact us to discuss your request. 6.3 You may only transfer Sterling from your MarketMaster Account to your International Trader Account. If you wish to trade in Euros and/or US Dollars you must transfer such foreign currency to your International Trader Account from your Nominated Account. 6.4 You should only trade if you have sufficient cleared funds in your International Trader Account: Accordingly, it is your responsibility to check that in respect of each transaction you propose to undertake, you have checked that you have sufficiently cleared funds to do so before you trade. 6.5 We will credit cash dividends, gilt, bond interest and other payments to your International Trader Account upon receipt. Dividends and interest payments (if paid in a currency other than Sterling) will be credited 5

6 to your International Trader Account in the foreign currency of the sub-account where the Investment is held, following deduction of any applicable tax. Such sums will only be available to you following market settlement of such payment and it will not be possible to automatically reinvest dividends or to elect to receive shares in lieu of a dividend. 6.6 If you want to withdraw funds from your International Trader Account, you must give us instructions by telephone. On receipt of such an instruction, we will pay funds as follows, (i) Sterling, will be paid into either your MarketMaster Account on the next business day or into your Nominated Account within five Working Days of receipt of your instruction; (ii) Euros or US Dollars, will be paid into your Nominated Account within five Working Days of receipt of your instruction. It is your responsibility to check that you have sufficient cleared money before you instruct us to withdraw funds from your International Trader Account. 6.7 If you want to transfer Investments into your International Trader Account. We will only accept a transfer of Investments in registered (non-certificated) form and we will not be able to accept transfers of any bond products. Where you have multi-currency accounts, your investments will automatically be held in your Sterling account unless you instruct us otherwise. If this happens, you may be liable to pay any foreign currency exchange rate applicable upon sale of such investments. 7. Investment Research and Analysis (Additional to Section B Part 6 of the Barclays Terms) Through the International Trader Platform you may have access to information on investments and markets, such as research, investment analysis or commentary. You should not view these materials as a personal recommendation or as investment advice. You should consider seeking investment advice prior to dealing in any investment mentioned in these materials. 8. Dealing on your behalf and settlement (Additional to Section B Part 4 of the Barclays Terms). 8.1 Orders will be executed and settled only through the currency account in which the order is denominated. 8.2 If you buy Investments, you must have sufficient cleared cash in the particular currency account of your International Trader Account to settle your purchases, including any transaction fees, commissions and taxes, on the date that you give us the instruction and on the Settlement Date. If settlement of any purchase will take place in a currency other than Sterling, you must have enough foreign currency in the International Trader Account to settle the transaction, having regard to the above costs and any fees applied in relation to any foreign currency conversion you require us to make. You must give us any instruction to convert one currency to another so that can complete before settlement of a purchase order. 8.3 If you sell Investments, you must have sufficient Investments available in your International Trader Account on the date that you instruct us to sell and on the Settlement Date. Sale proceeds will be credited to your International Trader Account on the Settlement Date. 8.4 You may buy or sell Investments without limit provided that you have sufficient cleared funds or Investments in your International Trader Account to settle your transactions in accordance with paragraphs 8.2 and 8.3 above. 8.5 Any instruction to effect a currency conversion in respect of any monies held in your International Trader Account will be effected on our behalf by the Platform Operator and will be at the foreign exchange rate provided by the Platform Operator. Details of the foreign exchange rate used to convert the currency will be specified in valuation statements provided via the International Trader platform. 8.6 If you place an order that is to be partially fulfilled as and when the conditions for the order being capable of being obtained, such order may result in multiple executions until the order is discharged in full. Each execution made in partial fulfilment of the order may result in costs, charges or commissions levied in accordance with Paragraph 11. 6

7 9. Our custody services and holding cash for you (Additional to Section B, Part 7 of the Barclays Terms) 9.1 We will provide you with Custody Services in relation to your International Trader Account as described in Section B Part 7 of the Barclays Terms and you should read these terms carefully, as they contain important provisions regarding the arrangements under which assets may be held on your behalf. 9.2 Where we consider it appropriate and in accordance with regulatory requirements, your Assets may be pooled with those of other clients (including other clients of sub-custodians) in an omnibus account. In that case, individual client entitlements may not be identifiable by separate certificates, or other physical documents of title, entries on the register or equivalent electronic records. If there is an irreconcilable shortfall following any default by us or our sub-custodian, you may not receive your full entitlement and may share in the shortfall in proportion to the value of the Assets which we hold for you with our other clients or the sub-custodian s, other clients. This Paragraph 9.2 is for information purposes and is not intended to limit any claim you may have against us in respect of a default. 9.3 Where there is a corporate event or other matter which involves the exercise of rights in relation to the Investments in your International Trader Account (a Corporate Event ), we may, at our absolute discretion, notify you and seek your instructions by sending you an electronic message on the International Trader Platform. It is your responsibility to check the International Trader Platform for such electronic messages from time to time. You may give us instructions in relation to Corporate Events by telephone or via the International Trader Platform. If we do not receive your instructions within any stated time limit, we will take no action. 9.4 In order to exercise any purchase rights in connection with a Corporate Event, you must have sufficient cleared funds in your International Trader Account at the time of your instruction and at the date of exercise of such purchase rights. We reserve the right not to act upon your instruction where there are insufficient funds in your International Trader Account. (Additional to Section B, Part 8 of the Barclays Terms) 9.5 We will hold money in relation to your International Trader Account as Client Money as described in the provisions of Section B, Part 8 of the Barclays Terms concerning holding cash as Client Money. You should read these terms carefully, as they contain important provisions regarding the arrangements under which Client Money may be held on your behalf. 10. Client Reporting (Additional to Section B Part 1 Paragraph 3 of the Barclays Terms) Transaction confirmation (contract note) 10.1 Each time that we buy or sell Investments on your behalf, we will send you an electronic confirmation note via the International Trader Platform. We will not send you a written confirmation note by post The International Trader Platform may issue a deal confirmation stating that a trade has been executed as soon as you have completed dealing instructions via the International Trader Platform. However, you cannot assume that any order placed through the Service has been executed until you receive an electronic confirmation note. Periodic valuation reports 10.3 You will be able to log in to your International Trader Account to view statements. We will not send by post periodic reports of the Investments held in your International Trader Account or the value of such Investments We will not provide you with any tax information about your Investments and you will be responsible for managing your own tax affairs in relation to the International Trader Account Any information that is displayed as an aggregated sterling value on your International Trader Account currency account represents an aggregate value of all cash held in all currencies. This means that you may not have enough cash in a particular currency to settle a transaction: If you carry out a transaction where you do not have sufficiently cleared cash, we will deduct the sum owed from the nominated 7

8 currency, first and thereafter from any other currency held in your International Trader Account to settle any shortfall. You may be liable to pay any foreign currency exchange rate applicable in respect of this. Accordingly, for each transaction you should ensure that you have sufficiently cleared funds in the relevant currency before you place your order. 11. Charges, Interest and Payment (Additional to Section A Paragraph 10 of the Barclays Terms) 11.1 We will collect fees and commission, and any taxes that we are required to charge you, by debiting your International Trader Account. Any fees, commission or taxes charged in respect of the Investment will be collected at the same time as any funds required to settle the purchase or sale of the Investment. Accordingly, you must make sure that there are sufficient cleared funds available in your International Trader Account to cover such fees, commission and taxes when they are due. If you do not have sufficient cleared funds to meet such fees, commission and taxes we may decline to act on your instruction Fees charged in relation to the operation and administration of the International Trader Account will be debited from this account. You must make sure that there are sufficient cleared funds available in your International Trader Account to cover such fees. If you open a MarketMaster Account in order to use the Services, but do not use your MarketMaster Account for any purpose other than to fund your International Trader Account, you may still be charged fees for the operation of your MarketMaster Account Any instruction to effect a currency conversion in respect of any monies held in your International Trader Account will be subject to a currency conversion charge payable by you We will share with the Platform Operator a proportion of the commissions and charges we levy on transactions entered into by you on the International Trader Platform and the currency conversions effected for you in relation to your International Trader Account. 12. Distance Marketing Directive Cancellation Rights (Additional to Section A Paragraph 14 of the Barclays Terms) 12.1 If the Agreement has been concluded without a face to face meeting between you and us and you are an individual (or individuals holding a joint account) rather than a corporate client, you have a right to cancel the Agreement with us within 14 calendar days from the later of: (a) the date of commencement of the Agreement (as specified in Section A of the Barclays Terms); and (b) the date on which the Barclays Terms were received by you Upon cancellation of the Agreement, you will not incur any cancellation fee, charge or penalty except that, where we carry out any transactions on your behalf prior to cancellation of the Agreement, we may require you to pay for any loss that we suffer in cancelling such transactions as a result of market movement If you wish to cancel the Agreement, you must notify us in writing at: Barclays, Tay House, 300 Bath Street, Glasgow G24LH (you may not use or other electronic communications for this purpose unless we have agreed otherwise If you cancel the Agreement, we may transfer any Investments we are holding for you into your own name, or transfer the Investments to another broker, or as you instruct. Where this is not reasonably practicable, you agree that we may sell the Investments at the prevailing market price. The amount that you receive will be reduced by any loss as a result of market movement in the period prior to cancellation. The sale proceeds will be returned to you no later than 30 days after the date that you notify us that you wish to exercise your right of cancellation. 13. Security and set-off (Additional to Section A Paragraph 22 of the Barclays Terms) 13.1 You should read carefully Paragraph 22 of the Barclays Terms, which explains our security interests and rights of set-off and how we may apply monies or 8

9 assets held within your International Trader Account (and any account you hold with us) if you fail to repay any outstanding sums, including overdrawn amounts, to us. 14. Termination (Additional to Section A Paragraph 11 of the Barclays Terms) 14.1 Your International Trader Account must not become overdrawn. If it does, in addition to paragraph 13 above, we may suspend the Services, freeze and/or terminate your International Trader Account. We will endeavour to provide you with notice of such action, but you acknowledge that if for example you have attempted to carry out multiple transactions on your International Trader Account, which has led to a negative balance, we may take such steps we deem reasonable to prevent your account from going into a negative balance in future The Service or any multi-currency sub-account may be terminated by giving you at least 30 days written notice. On termination, any currency held will be transferred to your Nominated Currency Bank Account. Any investments will be crystallised and the cash will be transferred to your Nominated Currency Bank Account. Where we are unable to transfer your foreign currency balance to your Nominated Currency Bank Account, we may in respect of an Investment, sell it, and in respect of currency balance, we may convert it into Sterling at the prevailing market rate and deduct any applicable foreign exchange costs in doing so We may delay the closure of your International Trader Account and the transfer of funds in order to process any outstanding transactions or payments of dividends or other income in relation to your Investments. This means that your currency remains at risk from exchange rate fluctuations and the final value of the sums transferred may be different to the value of your International Trader Account on the date you instructed us to terminate the Services. 15. Complaints (Additional to Section A Paragraph 27 of the Barclays Terms) 15.1 If you have a complaint about the Services, please contact: The Client Service Team, Barclays, Tay House, 300 Bath Street, Glasgow G2 4LH Telephone: * or local number * You can also contact us with a complaint through Contact Us when you are logged into your account online We will investigate your complaint in accordance with our complaints handling procedure and the FCA Rules. If we are unable to resolve your complaint to your satisfaction, you may be able to refer your complaint to the Financial Ombudsman Service, South Quay Plaza, 183 Marsh Wall, London E14 9SR (Tel: +44 (0) *). Further information about the Financial Ombudsman Service (including your eligibility to use the service) can be obtained from your usual contact at Barclays or from the Financial Ombudsman Service A leaflet containing full details of our complaints handling procedure is available on request and, in the event that you make a complaint, we will send a copy to you. 16. Law, jurisdiction and language (additional to Part A Paragraph 13 of the Barclays Terms) 16.1 The Agreement and our relationship with you will be governed by and construed in accordance with English law. The Agreement is supplied in the English language and all communication between you and us will be in English The Courts of England and Wales (subject to Paragraph 16.3) have exclusive jurisdiction to settle any dispute arising in connection with the Agreement including its creation, validity, effect, interpretation or performance and for such purposes the parties irrevocably submit to the jurisdiction of the courts of England and Wales. 9

10 16.3 Paragraph 16.2 is for our benefit alone. We retain the right to bring proceedings against you in our absolute discretion in the courts of any other country which may have jurisdiction to whose jurisdiction you irrevocably submit You agree to the service of legal process or any other documents in connection with proceedings in any court by the registered mailing of copies to your last address shown in our records or in any other manner permitted by English law, the law of the place of service or the law of the jurisdiction where proceedings are instituted. 10

11 Schedule A Execution Policy for International Trader Service How we execute client orders & the execution venues that we use Introduction Before we undertake any deals in investments for you, it is important that you understand how Barclays Bank PLC (BBPLC) will arrange such transactions. The following information is designed to provide you with a general understanding of our typical dealing arrangements and the execution venues available to us through our broker and platform provider. Please note that this information should not be seen as a prescriptive statement of how a particular order must be dealt with. BBPLC has selected Saxo Bank as the broker and platform provider for the International Trader Service. All dealing activities for this service will be undertaken by Saxo Bank and all order flow will be directed to them for execution. Saxo Bank may use other agents to execute transactions under this service. BBPLC has carried out appropriate due diligence on Saxo Bank to ensure that the execution quality meets our requirement to provide you with best execution under FCA rules. International Trader: The approach to best execution We identify and seek to obtain the most favourable terms reasonably available when executing an order on behalf of a client. To do this, we rely on two basic components: (i) use of technology to route orders to the execution venues or dealers offering the best prices available to us; (ii) where there is insufficient market liquidity for an automated execution or an order that requires specialised expertise to obtain the best result, the order will be handled by one of our dealing professionals. We maintain our dealing arrangements by performing regular checks on the results we achieve. When executing a buy or sell order, we will always consider: the nature of the client order; the characteristics of the financial instruments that are subject to that order; the characteristics of the execution venues to which that order can be directed. Automated Dealing: The role of technology in executing client orders We use automated systems to route and execute client orders. When a client order is received by us it is automatically routed to an execution venue that we believe will provide the best execution quality. This process aims to achieve the best price available to us at all times. For listed securities (cash equities) we will always route orders to an exchange or to an agent for execution. For OTC securities, the Platform Provider may fill the trade internally or will route orders to other market participants. Orders are only sent to firms that comply with limit order display and limit order protection rules. Many of these firms also provide automated executions for orders. Manual Dealing: Criteria for considering best execution Where we are not able to execute a deal using automated dealing technology our professional dealers will identify how to achieve the best possible result and deliver best execution of your order, taking the following factors into account: Price and cost Speed of execution Likelihood of execution and settlement Size and nature of the order Any other factors relevant to the execution of that order such as the characteristics of the financial instruments to which the order relates, as well as the possible execution venues to which the order can be directed. 11

12 When we trade we will determine the relative importance of these factors before we decide to deal. In general, we will regard price as the most important of these factors for obtaining the best possible result. However, we recognise that there may from time to time be circumstances where other factors may be prioritised in the interest of completing your instructions. For example speed and certainty of execution may be prioritised where the number of available execution venues or dealers available to choose from is limited. The execution venues that we use We primarily use regulated markets when arranging the execution of orders on your behalf. All equity trades are benchmarked to the pricing and liquidity in the primary regulated market for a selected company. Other market participants are used as order routing facilitators and in some cases an order will be filled internally or a trading venue other than the regulated exchange, if this will result in a better execution of the trade than if it was routed to the regulated market. You should only enter into the service if you are happy to consent to dealing outside of the regulated market in this way. The venues currently chosen include (but are not limited to): American Stock Exchange Euronext Amsterdam Australian Stock Exchange Athens Stock Exchange Euronext Brussels OMX Copenhagen Frankfurt Stock Exchange Hong Kong Stock Securities Exchange OMX Helsinki Euronext Lisbon London Stock Exchange SETS NAS-DAQ Capital Markets New York Stock Exchange Euronext Paris Singapore Exchange Securities Trading Limited Sistema De Interconexion Bursatil Espanol OMX Stockholm SWX Swiss Exchange SWX Europe Exchange Tokyo Stock Exchange Wiener Börse (Vienna) Stock Exchange NASDAQ Global Markets Borsa Italiana Services for disabled customers We are committed to providing equal access to our services for all customers with disabilities. Full details of Barclays services and facilities can be found in our brochure Disabled customers - making our services available. All of our literature can be provided in Braille, large print or audio tape on request, within a reasonable timescale, by calling * or local dial number *. *Calls to 0800 numbers are free if made from a UK landline and calls to 0141 numbers are charged at local rate, mobile costs may vary - please check with your telecoms provider. Calls may be recorded so that we can monitor the quality of our service and for security purposes. Our opening hours are 7.30am to 8.30pm Monday to Friday (excluding bank holidays) and 9.30am to 12.30pm on Saturday. Barclays offers wealth and investment management products and services to its clients through Barclays Bank PLC and its subsidiary companies. Barclays Stockbrokers is a trading name of Barclays Bank PLC which is a member of the London Stock Exchange and ISDX. Barclays Bank PLC is registered in England and authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Registered No Registered Office: 1 Churchill Place, London E14 5HP. Item Ref: BWL1419. March 2015