We understand the requirements of the FCPA and Bribery Act, the insider trading threats posed to investors in carrying out risk-related research, and the need for advisors to have comprehensive procedures in place to protect their clients. Ours include:
- A detailed written Code of Ethics and Practice that all our staff must follow, on which they are monitored during assignments and certified on an annual basis.
- Detailed policies for information gathering to avoid asking for, or transmitting on to clients, any privileged, confidential or material non-public information.
- Strict rules on the avoidance of conflicts of interest, including restrictions on stock trading by employees.
- Procedures for all reports and other sensitive communications to be vetted by our compliance officer before transmission to our clients.
- Monitoring all regulatory announcements and legislative changes to ensure we keep abreast of best practice.