Propose practices and procedures that head off breaches of the Code and Standards under Standard IV, Duties to Employers

An adequate compliance system under IV(C) is written, sized to the firm's business, communicated, followed and reviewed periodically; a code of ethics on its own is not enough. Firms should name a compliance officer with real authority, train staff, and avoid incentives that reward short-term performance at any cost. Outside roles such as paid directorships or consulting should require written disclosure and written consent before they start. Departure procedures should cut system access, recover firm records and model portfolios, and remind leavers of confidentiality. When a possible breach surfaces, procedures should require prompt investigation and interim limits on the employee. A supervisor who judges the procedures inadequate should tell senior management in writing and decline supervision until they are fixed.