10.3.1. Restrictions on investment analysts

An Authorised Firm must have arrangements in place to ensure that an investment analyst does not undertake a Personal Transaction in an Investment if the investment analyst is preparing Investment Research:

• (a) on that Investment or its Issuer; or
• (b) on a related Investment, or its Issuer;

until the Investment Research has been made available to its intended recipients, and those recipients have had a reasonable opportunity to act upon it.

10.3.2. Restrictions on own account transactions

An Authorised Firm or its Associate must not knowingly execute a transaction on its own account in an Investment or related Investments, which is the subject of Investment Research, prepared either by the Authorised Firm or its Associate, until the Investment Research has been made available to its intended recipients, and those recipients have had a reasonable opportunity to act upon it. This restriction does not apply if:

• (a) the Authorised Firm or its Associate is following a Market Making Strategy in the relevant Investment;
• (b) it is not expected to materially affect the price of the Investment.