Propose practices and procedures that head off breaches of the Code and Standards under Standard VI, Conflicts of Interest

Personal trading rules are the main defence: preclearance of employee trades, blackout periods around client orders and portfolio rebalances, duplicate broker confirmations sent to compliance, holdings reports on joining and periodically, and a ban on, or preclearance for, IPOs and private placements. Where in-house products sit alongside client accounts, a policy should govern cross-trades and the use of in-house funds, with each choice justified on merit and disclosed. Incentive fee terms should be explained so clients see the risk-taking they may encourage. Directorships should need prior approval and be disclosed in client reports. Referral arrangements should be approved in advance by the employer and disclosed in writing to clients with their estimated value. Preventive checks beat after-the-fact reviews.