Liffe all traders

Following NYSE Liffe London Settlement Circulars and Notices from the Financial Services Authority (FSA),
which provide summaries of rule breaches and details of the sanctions imposed on traders and firms who are
found to have breached the rules, ABN AMRO Clearing Bank N.V. would like to remind you of some specific
NYSE Liffe trading rules and procedures for:

Trading Rules - Prohibited practices.

Order Splitting and Testing.
Price Manipulation.
Automated Price Injection Models (APIMs).
Bandwidth Usage.
We recommend that you read, print and keep a copy of this information for future reference.

SECTION 4 - TRADING RULES

4.3 Prohibited practices

4.3.1 (a) In relation to any aspect of LIFFE Business or in relation to any aspect of business connected
with LIFFE Business, a Relevant Person shall not engage in practices which might reasonably be expected to
have an adverse effect on the operations of the Market or result in unfairness to his client(s) or
other Market participants.

(b) Notwithstanding the generality of, and without prejudice to, the remainder of this LIFFE Rule 4.3.1, a relevant
person shall not engage in the following practices or behaviour:

(i) price manipulation or cornering of the Market;

(ii) where a Relevant Person creates a misleading impression of activity occurring in the Market and/or causes
theExchange to report a misleading price level ("a wash transaction");

(iii) where a Relevant Person knowingly, or having reason to know, enters into a contract or contracts in an
attempt to conceal a potential or actual trading abuse by himself or some other party ("an accommodation
transaction");

(iv) where a Relevant Person deliberately trades, or places orders to trade, in the same direction (purchase or
sale) as a client order with a view to realising a profit pursuant to any price movement brought about by the client
order ("front-running");

(v) where a Relevant Person assigns trades rightfully due to a client to another account. For the avoidance of
doubt, aRelevant Person may be deemed to be engaging in this practice if such trades are assigned to the
other account in error for whatever reason where the situation is not subsequently remedied due to a failure to
act on the part of the Relevant Person;

(vi) withdrawing or withholding a clients order, in whole or in part, for the benefit of a Relevant Person or any
other firm or individual;

(vii) taking advantage of a client order for the benefit of a Relevant Person or any other firm or individual; and

(viii) where one or more Relevant Persons executes one or more trades the principal rationale of which is to
effect a monetary transfer between accounts in a concealed manner without creating or eliminating open interest
or for no legitimate purpose ("a compensation trade").
Order Splitting and Testing.

Order splitting is prohibited under Rule 8105, which prohibits Members from engaging in practices which may
cause degradation of the NYSE Liffe trading platform, and/or Rule 8102 which prescribes that members must
behave in a responsible manner when using a NYSE Liffe trading platform. This rule also applies to the
submission of test orders in the live environment which is prohibited and the test environment should be used.

EURONEXT RULE BOOK BOOK I: HARMONISED RULES

CHAPTER 8:

RULES OF CONDUCT

8105 USE OF EURONEXT TRADING PLATFORMS

8105/1 When using a Euronext Trading Platform and associated facilities, a Member is
prohibited from engaging in practices which may cause degradation of the service or
give rise to a disorderly market. Such practices include, but are not limited to,
submitting unwarranted or excessive electronic messages or requests to a Euronext
Trading Platform.

CHAPTER 8:

RULES OF CONDUCT

8.1. GENERAL

8101 SCOPE OF CHAPTER 8

8101/1 This Chapter 8 sets forth rules of conduct specific to the Euronext Markets which the
Members must observe when trading on such Markets.

8102 GENERAL DUTIES OF INTEGRITY, FAIR DEALING AND CARE

8102/1 When trading on the Euronext Markets, a Member shall:

(i) observe high standards of integrity, market conduct and fair dealing;

(ii) act with due skill, care and diligence; and

(iii) refrain from any act or course of conduct which is likely to harm the reputation
of Euronext or any Euronext Market.

8102/2 A Member shall behave in a responsible manner when using a Euronext Trading
Platform and associated facilities provided by a Euronext Market Undertaking and
shall only

The manipulation of futures settlement prices and option reference prices is prohibited under rule 8104 No
Fraudulent or Misleading Conduct.

EURONEXT RULE BOOK BOOK I: HARMONISED RULES

8104 NO FRAUDULENT OR MISLEADING CONDUCT

8104/1 In conducting business for itself or on behalf of its Clients, a Member must not engage
in, knowingly facilitate or fail to take reasonable steps to prevent:

(i) any action or any course of conduct that has the effect, or may be expected to
have the effect, of artificially and/or abnormally moving the price or value of
any Admitted Financial Instrument or any instrument underlying an Admitted
Financial Instrument or the level of any index of which an Admitted Financial
Instrument is a component;

(ii) entering artificial orders or otherwise entering into or causing any artificial
Transaction;

(iii) reporting a fictitious Transaction or any other false data to Euronext or

causing such data to be input into any Euronext system;

(iv) any action or any course of conduct that creates or may reasonably be
expected to create any false or misleading impression as to the market in, or
price or value of, any Admitted Financial Instrument;

(v) any other action or any other course of conduct that may damage the integrity
and the transparency of any of the Euronext Markets; or

(vi) agreeing or acting in concert with, or providing any assistance to, any Person
(whether or not a Member) with a view to or in connection with any action or
course of conduct referred to in paragraphs (i) to (v) inclusive of this Rule
8104 or otherwise causing or contributing to a breach of any applicable Rule
by such other Person.

The General Notice (2260) below is to remind you of the requirement to register Automated Price Injection
Models (APIMs) used on NYSE Liffe with the Exchange.

GENERAL NOTICE NO: 2260

ISSUE DATE: 5 August 2003
EFFECTIVE: 5 August 2003
REGISTRATION REQUIREMENT FOR AUTO ORDER INPUT TOOLS ON
LIFFE CONNECT

Executive Summary
This General Notice confirms the registration requirements for auto order input
tools on LIFFE CONNECT.

1. Introduction
1.1 General Notice No. 1901, issued on 16 October 2001, introduced registration
requirements for the use of Price Injection Models and a Charging Structure
for LIFFE CONNECT Bandwidth usage. This General Notice is
supplementary to General Notice No. 1901.

1.2 One of the unique strengths of LIFFE CONNECT continues to be its open
architecture and the ease with which software vendors and those using
proprietary software can write to the API. The Exchange has permitted ever
more sophisticated software to be deployed by users onto the system,
including a wide variety of price injection models.

1.3 In recent months new tools, which automatically create and execute spreads
between markets, have become particularly popular. The purpose of this
General Notice is to make it clear that these new tools constitute a type of
Automatic Price Injection Model (APIM). Accordingly, members are
reminded that all users of such tools, and any other type of APIM, must
register their usage with the Exchange (as per General Notice No. 1901).
Equally, members are reminded that all such software must pass conformance
with Technical Conformance Services. The attached registration form should
be used for the registration of all APIM tools not already registered with the
Exchange. Forms should be returned to the Exchange no later than Monday
18 August 2003.

1.4 No member will be permitted to use an APIM which has not been registered
with the Exchange, and members are responsible for registering any APIM(s)
operated by their client(s). For the avoidance of doubt, an APIM operated by
a members client will be deemed to be an APIM of the member himself.

2. Registration of Automated Price Injection Models

2.1 An APIM is defined as an electronic system or computer software which:

(a) interfaces with the LIFFE CONNECT API;

(b) both determines the requirement for sending, and sends, order handling
messages to the LIFFE CONNECT Trading Host without necessarily
requiring the intervention of an individual; and

(c) may automatically create and trade inter- market and intra-market
spreads simultaneously.
Accordingly, included within this definition are tools which automatically
create and execute spreads between markets. Any member who is unclear
about the application of this definition to a particular model or system should
contact their Account Manager, who will confirm whether the particular model
or system needs to be registered.

2.2 All APIMs must conform with the LIFFE CONNECT Developer Guidelines
for Automated Price Injection Models, which are available at:
www.liffe.com/access/developers/index.htm

2.3 All Members utilising APIMs will be given a daily message allocation. The
daily message allocation will depend on the contracts to be traded, and the
style of trading to be undertaken. Members should ensure that they are able to
"calibrate" their APIM software, such that the message allocation is not
breached.

2.4 Only those members who have registered the use of an APIM for a specific
contract, are using conformed software, and have been approved by the
Exchange, will be allowed to operate a model in that contract.
3. Appropriate usage of APIMs

3.1 Users of APIMs are prohibited from entering multiple orders at the same price
(also known as "multiple orders at depth"), since this is deemed to be anti
social behaviour proscribed by Rule 8105/1 (Rules, Book I). The Exchange
reserves the right to suspend a members access via a particular ITM or ITMs
following a verbal warning and/or to take disciplinary action in response to
such behaviour.

3.2 Users of APIMs will be monitored closely in order to ensure that their activity
is not damaging overall market quality or causing a degradation of service.
For example, traders using APIMs continuously to update prices which are
away from market value may likewise have their trading access suspended and
their orders pulled from the market.

3.3 All users of APIMs must ensure they do not breach their message allocation,
since this may result in selective fines being imposed by the Exchange.

3.4 All users of APIMs must undertake the relevant training from their chosen
software supplier, prior to using the software in the live market. Testing and
training can take place in the LIFFE CONNECT test environments, which
are available 22 hours a day.

4. Further Information and Member Feedback

4.1 Members should return completed APIM Registration Forms to Anne
Schouvey in Account Management (+ 44 (0) 20 7379 2184) at LIFFE by
Monday 18 August 2003.

4.2 Members seeking further information or wishing to provide feedback in

relation to this General Notice should contact their Account Manager at
LIFFE.

EXTENSION OF THE CHARGING STRUCTURE FOR LIFFE CONNECT

BANDWIDTH USAGE

GENERAL NOTICE NO: 2347

ISSUE DATE: 15 January 2004

EFFECTIVE: 2 February 2004

Executive Summary

This General Notice informs members of the extension of the charging structure for
LIFFE CONNECT bandwidth usage for those members who have registered an
Automated Price Injection Model with the Exchange.

1. Introduction
1.1 One of the unique strengths of LIFFE CONNECT continues to be its open
architecture and the ease with which software vendors and those using
proprietary software can write to the API. The Exchange has permitted ever
more sophisticated software to be deployed by users onto the system,
including a wide variety of Automated Price Injection Models ("APIMs").

1.2 The Exchange recognises the need to control the usage of APIMs in the
interests of the market as a whole in order to ensure that members are not
materially disadvantaged when executing business on LIFFE CONNECT,
whether they are using APIMs or not. Accordingly, General Notice No. 2260,
issued on 5 August 2003, requires members to register with the Exchange all
APIMs used when trading on LIFFE CONNECT. Once registered, members
are given a daily message allocation and are advised to ensure that they are
able to calibrate their APIMs such that they do not breach this allocation. The
daily message allocation is calculated by taking into account expected usage of
the APIM and can be revised at any time, with order activity being monitored
on a daily basis.

1.3 Members will be aware that, in certain circumstances, the use of APIMs may
lead to a degradation of service for market users generally. In order to prevent
this from occurring, the Exchange has decided to extend the charging structure
for bandwidth allocation breaches to all contracts traded on LIFFE
CONNECT. Currently the charging structure applies to the European-Style
FTSE 100 Index Option (ESX) Contract, Universal Stock Futures Contracts
and Individual Equity Option Contracts.

1.4 The charging scheme detailed in section 2 below replaces that outlined in
General Notices No. 1911 and No. 2124, issued on 31 October 2001 and 13
November 2002 respectively, with effect from 2 February 2004.

1.5 Members are reminded that APIMs must be registered with the Exchange, be
used in conjunction with conformed software, and have been allotted a daily
message allocation for each product in which the APIM is to be deployed
prior to being used.

2. Bandwidth Charging Scheme

2.1 The daily message allocation given to members consists of the number of
order submissions, revisions and withdrawals which may be used by the
member each day. There will be no charge for use of order messages up to
the daily allocation.

2.2 Separate notices will be issued by Euronext.liffe Brussels and Paris with
regard to APIM usage in those markets, and the charging structure will be
common to Euronext.liffe London, Brussels and Paris. The table contained in
paragraph 2.3 below details the charges applicable. For Euronext.liffe London
the charges will be calculated and payable in sterling and for all other markets
in euros. The charges may be subject to change from time to time as advised
by the Exchange.

2.3 Should the daily message allocation be exceeded by a member, charges will
apply according to the schedule below. The charges shall be calculated on
each day that the allocation is exceeded.

Message Usage Incremental Charge Per Message

Up to Allocation No Charge

Between 100% and up to 110% of Message Allocation 0.07 (0.10)

Above 110% and up to 120% of Message Allocation 0.14 (0.20)

Above 120% of Message Allocation 0.175 (0.25)

2.4 As an example, a member who uses 6,000 messages in the Euribor Futures
Contract on a single day (where the daily message allocation is 5,000) would
be charged:

(500 x 0.07) + (500 x 0.14) = 105.00 per day.

2.5 Whilst the charges will be calculated during the first three months of the
scheme (i.e. February 2004, March 2004 and April 2004), payment will not be
required to be made by any members who exceed their allotment during this
period. This is to provide members with sufficient time to ensure that their
APIMs are appropriately configured and for adjustments to be made to the
daily message allocation by the Exchange, in consultation with members.

2.6 The grandfathering period described in paragraph 2.5 above will not apply to
the European-Style FTSE 100 Index Option (ESX) Contract, Universal Stock
Futures Contracts and Individual Equity Option Contracts, for which a
charging scheme is already in place. For these contracts the revised charges,
as set out in paragraph 2.3 above, will apply from 2 February 2004 onwards.

By clicking the finish button below, you are confirming that you acknowledge and understand the
rules and agree to comply with them at all times.
ICE Rules & Regulation User Acknowledgment
ICE Futures Europe requires that we provide you with the ICE Rules and Regulations. Please find below a link to
the ICE website where you can view the relevant documents:

Section A - General
Section E - Disciplinary
Section F - Registration of Contracts
Section G - Trading
ICE Futures Electronic Trading Procedures
Please click on this link https://www.theice.com/FuturesEuropeRegulations.shtml or copy the link into
your web browser and read through the above listed sections.

We recommend that you also book mark this link for future reference.

Can you please confirm that you can access the necessary documents and that you have made yourself aware
of the rules and regulations before you commence trading on ICE. You must also keep yourself up to date of
future changes.

If for any reason you cannot access this information you must revert to ABN AMRO Clearing Bank N.V. in the first
instance.