✔ Firms who outsource important operational
functions are still liable for all regulatory
✔ Firms must be able to prove their outsourcing
partner has the ability, capacity and resources to
meet all regulatory obligations.
✔ The outsourced firm must be able to show it has
established methods for assessing its own standard
✔ Firms must ensure overseas outsourcing partners
are authorised or registered in their home country
and that a co-operation agreement exists between
the regulator of the firm and the regulator of the
✔ Research and communications staff should not
trade in a personal capacity on the basis of
knowledge obtained from corporate financial
✔ Chinese walls should exist between research
analysts and other persons in the business that
may become conflicted by learning of research
✔ Financial analysts should not accept financial
✔ Financial analysts should not promise favourable
✔ Those outside of the research team should not be
permitted to review a draft of investment research
prior to publication.
OF INTEREST POLICY
✔ Firms must have a conflicts policy which is
appropriate to the size of the company.
✔ The policy must clearly identify what constitutes a
‘conflict of interest’.
✔ The policy must include considerations on
remuneration as outlined in the pay and bonuses
✔ Senior management need to review the conflicts of
interest policy at least once a year.
✔ Companies should not ‘over rely’ on employee
disclosure of conflicts of interest and any attempt to do
so will be frowned upon under MiFID II rules.