The Volcker Rule requires that banking entities have policies and procedures in place to monitor or prevent material conflicts of interest. Specifically, the Volcker Rule requires that a banking entity that engages in any transaction, class of transaction, or activity that would involve or result in the banking entity’s interests being materially adverse to the interests of its customers with respect to the transaction, class of transaction, or activity address and mitigate the conflict of interest, where possible, through either timely and effective disclosure or through the establishment and enforcement of information barriers.

In the normal course of business, Stifel provides a variety of financial services to trading customers that may involve or result in conflicts of interests. The financial services provided to customers that also transact on the Firm’s trading desks include, among others, investment banking services, research services, and market-making services.

Stifel has implemented an Information Barrier Program that is designed, in part, to address conflicts of interests, such that the conflict does not have a materially adverse effect on a customer. This program includes information barriers between trading desks and between trading desks and other areas of Stifel that may possess information that may create a conflict of interest in relation to the activity of its trading desks.