CLIENT PROTECTION PRINCIPLES

In 2002, OTR Global, then known as Off The Record Research, voluntarily adopted the Investment Protection Principles, created between Merrill Lynch and Co. and the New York State Attorney General, which highlights OTR’s ability to operate free of investment banking conflicts. The Firm's Client Protection Principles go beyond ensuring that the research delivered to its clients is free of internal conflicts. The research creation process ensures that any obligations of the research/sources are addressed and OTR’s clients are protected from legal and regulatory concerns.

• OTR Global has no investment banking division; in fact, the firm has no service that a subject company in its research products could utilize
• OTR receives no compensation from any of the subject companies in its research products
• The sources used by OTR are not paid for the information they provide, which allows the sources to present their views in a conflict-free, unbiased environment
• OTR utilizes multiple sources for each research report, as opposed to one research consultant. This allows the research to be an in-depth, broad picture of the marketplace without the potential for conflicted sources
• OTR does not allow direct contact between the client and the sources of its research. This protects the anonymity of the source and allows the Firm to oversee the creation of the research to ensure all parties' legal obligations are protected
• The vast majority of OTR's global sources are not affiliated with the subject companies of the research