A method of protecting confidential information from disclosure.

A: Introduction In exceptional circumstances, we may act for a client where we hold material confidential information about another (existing, former or prospective) client. Where this happens, we must be able to safeguard material confidential information as between the respective clients and obtain the informed consent of some or all of the affected parties. We may also exceptionally act for a client where we hold confidential information about a non-client, which is subject to a contractual or other obligation of confidentiality. This plan: • identifies the way in which information can move within the firm, and • sets out the measures we have established as part of the organisational structure of the firm to safeguard material confidential information B: General principles On a case-by-case basis, when a confidentiality issue arises, the [COLP OR supervising partner] will consider: • whether it is appropriate and feasible to act on the basis that we can safeguard material confidential information and, if so, which of the measures set out in sections D to G of this plan to adopt • the client consent requirements If information barriers are required, they will be established

Information barrier plan prepared by [insert name] Information barrier plan approved by [insert name of partner and/or COLP] Date [insert date] A: Client and matter details Name of first client to whom the information barrier will apply [insert name of first client to whom the information barrier will apply] Matter description and file reference for first client [insert matter description for client 1] Partner in charge for first client [insert name of partner] Name of second client to whom the information barrier will apply [insert name of second client to whom the information barrier will apply] Partner in charge for second client [insert name of partner] Matter description and file reference for second client [insert matter description for client 2] Partner in charge for third client [insert name of partner] Name of third client to whom the information barrier will apply [insert name of third client to whom the information barrier will apply] Matter description and file reference for third client [insert matter description for client 3] Do we need consent of any client? Yes/No If yes:• which clients? • do we have consent? [State:]• [which clients]

Information exchange is a regular commercial practice which can increase transparency of price and other commercially sensitive information and, in some instances, generate efficiencies. Information exchange is being increasingly targeted as an anti-competitive practice. At the same time, information exchange remains one of the most challenging areas for the application of competition law. Examples of relevant conduct include alleged price signalling, exchange of information and bid-rigging, unilateral disclosure of information about pricing intentions, indirect exchanges of information, information exchange through an intermediary, information exchange in initial public offerings and share placing or information exchange between merging parties. This Practice Note considers the application by the European Commission (Commission) of Article 101 TFEU to agreements and concerted practices involving the exchange of information. For a consideration of information exchange from a UK competition perspective, see further, Information exchange under UK competition law. On 1 June 2023, the Commission adopted new Guidelines on the applicability of Article 101 TFEU horizontal co-operation agreements (Horizontal Guidelines). These contain revised, restructured and expanded guidance on information exchange, reflecting

Information exchange is a regular commercial practice which can increase transparency of price and other commercially sensitive information and, in some instances, generate efficiencies. Information exchange is being increasingly targeted as an anti-competitive practice. At the same time, information exchange remains one of the most challenging areas for the application of competition law. Examples of relevant conduct include alleged price signalling, exchange of information and bid-rigging, unilateral disclosure of information about pricing intentions, indirect exchanges of information, information exchange through an intermediary, information exchange in initial public offerings and share placing or information exchange between merging parties. This Practice Note considers the application by the Competition and Markets Authority (CMA) (and sectoral regulators) of the Chapter I prohibition of the Competition Act 1998 (CA 1998) to agreements and concerted practices involving the exchange of information. For a consideration of information exchange from an EU competition law perspective, see further Practice Note: Information exchange under EU competition law. Framework for the assessment of information exchanges In order to find an infringement of the Chapter I prohibition

Welcome to the Information Law yearly highlights for 2024: a hand-picked chronological summary of major news analysis and updates related to laws governing the use and dissemination of information and personal data. These highlights look back on developments in key topics such as data protection, ePrivacy, cybersecurity, breach of confidence, misuse of private information, and defamation. Key areas to watch for 2025 are also explored.

1 General information Date of review [insert date of review] Date of last review [insert date of last review] Person(s) conducting review [insert name(s) or role(s), eg data protection officer] 2 Review and findings Have you checked your Data processing register is up to date? ☐ Yes☐ NoIf no, ensure you set an action point at section 3 below Have you conducted a data protection risk assessment since the last review? ☐ Yes☐ NoIf no, ensure you set an action point at section 3 below Have you conducted an information security review since the last review? ☐ Yes☐ NoIf no, ensure you set an action

This Practice Note explains the key regulatory and statutory provisions governing the management and security of information and data, referred to as information management and security. SRA You must keep the affairs of clients confidential unless disclosure is required or permitted by law or the client consents. The SRA expects you to identify, monitor and manage all material risks to your business. You are also under a duty to safeguard money and assets entrusted to you by clients and others. UK General Data Protection Regulation (UK GDPR) Assimilated Regulation (EU) 2016/679 (UK GDPR) imposes extensive requirements around information security, record-keeping and general information management. For more guidance, see Practice Note: How to comply with information security requirements and Precedent: Small business GDPR compliance—self-audit. The UK GDPR security principle Data security is a cornerstone of the UK GDPR. You must process personal data in a manner that ensures appropriate security (using appropriate technical or organisational measures), including protection against: • unauthorised or unlawful processing, and • accidental loss, destruction or damage The UK GDPR

A document produced by the borrower/issuer and arranger/lead manager of a syndicated loan/securities issue to inform potential lenders/investors about the borrower/issuer and the nature of the loan/securities

VERIFICATION NOTES Verification notes (the Notes) for the information memorandum (the Information Memorandum) prepared by [insert name of the seller] (the Seller) with the assistance of [insert name of financial adviser] (the Financial Adviser) in connection with a possible disposal by the Seller of [insert description of the company or business and assets to be sold, eg ‘the entire issued share capital of XYZ Ltd’ or the business of XYZ Ltd’] (the Proposed Transaction). These Notes have been prepared by [insert details of seller's solicitors] for the purpose of assisting the directors of the Seller (Directors) and others concerned with the Information Memorandum and the Proposed Transaction to comply with their legal obligations. The Notes have been designed to record, as far as practicable, the steps which have been or are being taken to check the truth and accuracy of the factual information contained in the Information Memorandum, to record who has confirmed that particular statements of fact are correct and to check the accuracy of the facts upon which forecast, estimate or expressions

Failure to provide adequate costs estimates is one of the most common causes of client complaints and disciplinary action by the Solicitors Regulation Authority (SRA). This Practice Note explains the regulatory requirements that you must comply with in relation to providing costs information to your client. It reflects the SRA Codes of Conduct and requirements that apply under the SRA Transparency Rules. Where relevant, this Practice Note also incorporates: • guidance issued by the Law Society • expectations of the Legal Ombudsman (the LeO), as articulated in An ombudsman’s view of good costs service and • Lexcel requirements—which are compulsory for firms with, or working towards Lexcel accreditation, but generally reflect good practice for other firms See also Precedents: Client care letter—law firms and Terms of business—law firms. Expectations of the Legal Ombudsman Costs complaints often escalate to the Legal Ombudsman rather than the SRA. It is therefore worth familiarising yourself with the LeO’s general approach to what constitutes good practice on solicitors’ costs. ‘Good cost information will always be a central feature of a reasonable

This Checklist is designed to help you determine whether you have the systems in place to comply with regulatory requirements that apply to law firms in relation to information on costs. It reflects the requirements of the SRA Standards and Regulations. It should be read in conjunction with subtopic: Information on costs. For information and guidance about fee sharing arrangements and referral fees, including what information you are obliged to provide to clients, see subtopic: Referrals and fee sharing. Amount of costs Requirement Compulsory or recommended Comments (if any) ☐ Ensure clients receive the best possible information (at the outset and as appropriate as the matter progresses) about:—how their matter will be priced and—the likely overall cost of the matter and any costs incurred, at the time of engagement and when appropriate as their matter progressesSee Precedent: Client care letter—law firms. Compulsory SRA Code for Solicitors, para 8.7SRA Code for Firms, para 7.1 (Insert any comments you may wish to make regarding your firm’s arrangements) ☐ Ensure the costs information you provide to clients includes:—the