Propose practices and procedures that stop breaches of the ethics Code and the Standards of Professional Conduct before they occur

Recommended practices for duties to clients: written allocation procedures fixed before orders are placed, with time-stamped tickets and pro rata allocation of partial fills in round lots, and simultaneous release of rating changes. For suitability, a written IPS covering risk, return and constraints, reviewed at least annually and before material changes, plus a discussion and, where firm policy calls for it, a signed acknowledgement when a client insists on an unsuitable trade. For loyalty, a written proxy voting policy disclosed to clients and at least quarterly itemised statements. For performance, composites that include terminated accounts, clear labels on simulated or prior-firm results and a statement of whether returns are gross or net of fees, with GIPS compliance as best practice. For confidentiality, secure data handling on a need-to-know basis.