Research Conflict Management Policies

This document provides an overview of Morgan Stanley’s policies governing investment research published by the Research Department of Morgan Stanley¹ and its affiliated companies (“the Firm” or “Morgan Stanley”)². Morgan Stanley Research is committed to delivering high-quality, objective, independent, and unbiased research. While our policies generally apply globally to maintain research independence, certain policies may differ based on regional rules, regulations, and local business practices.

Morgan Stanley’s policies and internal procedures are designed to help the Firm identify and manage actual, potential, or perceived conflicts of interest that could affect, or appear to affect, the impartiality or independence of its research. Such conflicts may arise in connection with investor clients, sales and trading activities, investment banking activities, wealth management activities, corporate clients, and the interests of the Firm’s officers and employees.

Mechanisms for identifying and managing potential conflicts include, but are not limited to:

•     providing internal guidance and training to research analysts and other Firm personnel on identifying potential conflicts;
•     adopting procedures reasonably designed to ensure that identified or potential conflicts are escalated appropriately;
•     monitoring and implementing controls to confirm conflicts are managed appropriately;
•     monitoring the publication of research in the period before, during, and after investment banking transactions;
•     implementing and maintaining systems and processes to facilitate the required disclosures in research reports; and
•     maintaining and enforcing employee certification protocols that require the disclosure of personal conflicts, including any compensation received in connection with specific recommendations, and confirmation that the views expressed accurately reflect the analyst’s own views.

Supervision: Research analysts are not directly supervised by personnel engaged in investment banking,³ sales and trading, or other areas of the Firm whose interests or functions may conflict with the objectivity of research analysts. Senior Research Management personnel report directly to Firm Management or to the most senior management level in the related sales and trading business.

Evaluation and compensation: The evaluation of research analysts for purposes of career advancement, compensation, and promotion is structured to prevent non-research personnel from exerting inappropriate influence over research analysts. The compensation of research analysts is based on established criteria, including the quality and accuracy of research. Research analysts’ compensation may not be directly linked to specific transactions or the profitability of particular trading desks or investment banking groups, but it may in part reflect the overall profitability of the Firm as a whole, including the profitability of the investment banking and sales and trading businesses.

Morgan Stanley does not permit investment banking personnel to participate in the Firm’s evaluation of research analysts and limits the participation of sales and trading personnel in the Firm’s evaluation of research analysts in accordance with regulatory requirements.

Morgan Stanley is committed to maintaining the independence, objectivity, and integrity of its research. To support this commitment, the Firm has established policies that restrict research analysts from engaging in activities that could compromise, or appear to compromise, the independence of their research. In particular:

• Research analysts are not permitted to participate in efforts to solicit investment banking business or to participate in investment banking pitches to prospective investment banking clients.
• Research analysts may not attend road show presentations by issuers that are corporate clients of the Firm in connection with securities offerings or other investment banking transactions. They may, however, observe road shows in listen-only mode solely to access the same information made available to investor clients.
• Research analysts may not be involved in promotional or marketing activities of an issuer of a relevant investment that would reasonably be construed as representing the issuer.
• Research analysts may not receive material non-public information regarding an issuer or investment except where such access has been approved in accordance with Morgan Stanley’s wall-crossing and information barrier policies and procedures. Research analysts who possess material non-public information may be restricted from certain activities until such information has become public or stale.

Subject to restrictions in certain jurisdictions, research analysts may, where permitted, undertake the following activities:

• attend ordinary-course investor presentations (also known as non-deal roadshows), including those hosted by Firm clients, provided that such events do not promote securities offerings or other investment banking transactions;
• provide investment banking and sales and trading personnel with insights into market and industry trends, conditions, and developments, as well as the structuring, pricing, and expected market reception of securities offerings or other market operations;
• conduct due diligence and vetting of issuers who may be prospective subjects of research or prospective investment banking clients and, subject to jurisdictional restrictions, meet with issuers for those purposes; and
• educate investors and the Firm’s sales force in connection with an investment banking transaction.

Research analysts’ personal dealings: Research analysts⁴ are generally prohibited from trading securities or related derivatives of any issuer on which they issue research, or from trading in the discipline they cover. This restriction may include companies in an analyst’s area of coverage and investment funds whose performance, at the time of purchase or sale, is materially dependent on the performance of securities in their coverage area.

Where personal account trading is permitted, all Morgan Stanley employees must comply with the Firm’s policy restrictions and requirements, including monitoring, pre-approval, and disclosure of positions that may create the appearance of a conflict of interest.

Inducements: Morgan Stanley prohibits research analysts from soliciting or accepting any inducement to produce favorable research on an issuer. These restrictions do not preclude the acceptance of reasonable hospitality in accordance with the Firm’s general policies on gifts, entertainment, and corporate hospitality.

Inappropriate influences: Morgan Stanley has implemented policies and procedures to regulate, where appropriate, communications between research analysts and non-research personnel that could be perceived as resulting in inappropriate influence over analysts’ views. These measures include:

• physical separation and information barriers between research personnel and investment banking and sales and trading personnel;
• investment banking, sales and trading, and other non-research personnel may not direct a research analyst to publish a research report or attempt to inappropriately influence an analyst’s views or the content of a research report; and
• Research Management has final authority over decisions to initiate, resume, suspend, or discontinue research coverage of an issuer or investment and may consider input from other business areas to the extent permitted by applicable laws, rules, and regulations.

Certification on each research report: The primary research analyst responsible for a research report on a specific issuer or issuers of securities is required to certify, at the time of publication, that the views expressed in the report accurately reflect the analyst’s personal views about the subject securities or issuers, and that no part of the analyst’s compensation was, is, or will be directly or indirectly related to the specific views or recommendations contained therein. This certification can be found in the disclosures section of each such research report.

Morgan Stanley’s policies and procedures are reasonably designed to limit the ability of parties whose interests may conflict with those of clients receiving research to review or comment on research in a way that could compromise its impartiality.

Review of research: Morgan Stanley maintains editorial guidelines and procedures for supervisory and compliance review of research prior to publication. Research reports that discuss a company or other entity in relation to which Morgan Stanley has an investment banking mandate, which is not necessarily limited to the issuer that the Firm represents in that mandate, are reviewed by the Legal and Compliance Division (“LCD”) to monitor compliance with legal or policy restrictions, including applicable local regulatory restrictions, on timing or content.

Subject to Morgan Stanley’s policies and procedures, and with prior approval from LCD, a research analyst may verify the accuracy of factual statements with the relevant issuer that is the subject of a research report. Where permitted, reports prepared by non-U.S.-based research analysts and intended for distribution prior to an initial public offering of a non-U.S. company’s shares may be reviewed by investment banking personnel solely for factual accuracy. Research analysts must provide a rationale for any subsequent material change made following a factual review by an issuer or, where permitted, non-research personnel. Any such changes must be approved by Research Management and LCD prior to publication of the report.

Role of review committees: The Research Department utilizes review committees composed of senior members of the relevant regional research departments and, where appropriate, members of other departments, excluding investment banking personnel. These committees review research reports prior to publication to promote high-quality research content and to help safeguard research analysts from undue influence by other employees, issuers, or investors.

Complaints: Complaints concerning the content of research reports are referred to LCD and/or Research Management for review in compliance with the Firm’s complaint handling procedures, which are reasonably designed to prevent influence or pressure on the covering research analyst.

Retaliation policy: The Firm and non-research personnel may not retaliate, or threaten to retaliate, against any research analyst for negative or otherwise unfavorable research that may adversely affect the Firm’s current or potential investment banking relationships or its current or prospective trading or clearing activities.

Morgan Stanley’s policies and procedures are reasonably designed to help ensure that decisions regarding the timing and content of research are not made by, or inappropriately influenced by, parties whose interests may conflict with those of clients receiving research, and that new, material views are not selectively disclosed before broad dissemination.

Investment banking and sales and trading personnel have no control over, and no input into, decisions regarding the timing of publication of individual research reports.

The Firm’s policies and applicable laws or regulations may restrict the publication of research, or the inclusion of opinions or recommendations in research, relating to an issuer or its related parties at certain times when the Firm is involved in investment banking transactions. The nature, timing, and duration of any restriction depend on the nature of the transaction.

Dissemination of research and updated views: Research reports are made available to clients through Morgan Stanley’s proprietary Matrix Platform and are also distributed electronically to clients by Morgan Stanley. Certain, but not all, research products are also provided to clients through third-party vendors or through alternate electronic channels as a convenience. Morgan Stanley policies prohibit the distribution of research reports to non-research personnel within the Firm prior to their release to all Morgan Stanley research clients.

Disclosure of conflicts of interest: In accordance with applicable laws and regulations, the Firm discloses in its research reports any conflicts of interest—including those of the Firm and the research analyst—that are, or may be, material in the context of the relevant report.

This policy is available from Morgan Stanley upon request and on the Morgan Stanley website at www.morganstanley.com/what-we-do/research/management-policies. Morgan Stanley reserves the right to amend or supplement this policy at any time.

This policy is supplemented by more detailed policies and procedures adopted by the Firm. Variations and exceptions to this policy may be approved by Research Management and LCD in individual cases, where doing so would further the policy’s objectives in particular circumstances.

This policy is not intended to create third-party rights or duties that would not otherwise exist, or to constitute or form part of any contract between the Firm and any client, customer or other person.

June 2026