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Memorandum

To: All U.S. Individuals Associated with Barclays Capital, Inc. (“BCI”) and Barclays Wealth
Americas (“BWA”)

From: Erin Mansfield, Director of Compliance, Americas

Date: July 2009

Subject: Employee Acknowledgement and Disclosure Package

As part of our ongoing dedication to compliance with both internal policy and external regulatory
requirements, all newly hired individuals are required to complete the Compliance disclosure forms
listed below within 30 days of joining the Firm.

***Please note that each of these forms must be signed and returned, even if
you have nothing to disclose. ***

 Personal Account (“PA”) Disclosure Form


All personal brokerage accounts and those of “connected persons” must be disclosed to
the Compliance Department.
All personal brokerage accounts and those of “connected persons” must be maintained
with an approved broker, unless an exemption has been granted by the Compliance
Department.
All relevant accounts are required to be transferred to an approved broker within 60
days of joining the Firm.
BCI and Barclays Wealth Americas (“BWA”) employees require pre-approval by a
Supervisory Director (or above) as well as from BCI or BWA Compliance for all personal
account transactions.
For additional information regarding personal account restrictions, please consult the
Global PA Dealing Policy.
 Outside Affiliations Disclosure Form
BCI employees require pre-approval by a Supervisory Director for all outside business
affiliations, regardless of whether the relationship is by virtue of your employment with
Barclays Capital.
BWA employees require pre-approval by their Branch Administrative Manager as well as
BWA Compliance.
This includes, but is not limited to directorships, partnerships, advisory positions and
other private ventures, whether compensated or not.
Compensation received for work conducted on behalf of your association with Barclays
Capital may be required to be paid directly to the Firm.
 Outside Investment Disclosure Form
BCI employees require pre-approval by a Supervisory Director for all outside investment
activities.
BWA employees require pre-approval by their Branch Administrative Manager as well as
BWA Compliance.
This includes, but is not limited to interest as a general or limited partner in a private
partnership or hedge fund and stock or other economic interest in a non-public
company.
Significant and/or material shareholdings in a company.
All original forms with all of the required signatures should be returned to the Human Resources
Department located at 200 Park Avenue, 29th Floor, New York, NY, 10166.
Please refer to the Firm’s Global Personal Account Dealing Policy and Global Outside Business
Affiliations and Outside Investments Policy for additional guidance. Both policies are available on the
Barclays intranet.
Any additional questions should be directed to the contacts listed below:
Personal Account Dealing - PA Dealings Hotline (212) 526-5511
BCI Outside Affiliation/Investment Inquiries - Keith Andre (212) 412-2241
BWA Outside Affiliation/Investment Inquiries – BWA Compliance
Lastly, over the course of the next few weeks, based on your organizational department, you will be
receiving email notifications to complete a series online Compliance training modules. These courses
will cover a broad range of Compliance issues that the Firm deems critical to your understanding of the
organization, your job function and compliance obligations. These courses are MANDATORY and will
be electronically tracked for completion.