1.Principals We will strive for the highest ethical standards and create a strong culture of ethical and professional conduct with regards to Market activities through the following:
Ethics training by relevant staff, employee code of conduct, senior management to be highly visible to all personnel in articulating and modelling the desired practices, values, and conduct.
2. Governance. We will have remuneration and promotion structures that promote market practices and behaviours that are consistent with our ethical and professional conduct expectations. We will have appropriate policies and procedures to handle and respond to potentially improper practices and behaviours effectively.
We handle orders fairly and with transparency in line with the capacities in which we act.
We will not request transactions, create orders, or provide prices with the intent of disrupting market functioning or hindering the price discovery process.
We will identify and resolve trade discrepancies as soon as practicable to contribute to a well-functioning Market.
As a firm relying on trading algorithms, we will provide adequate disclosure regarding how they operate.
4. Information Sharing
We will clearly and effectively identify and appropriately limit access to Confidential Information.
We will communicate in a manner that is clear, accurate, professional, and not misleading.
We will provide personnel with clear guidance on approved modes and channels of communication.
5. Risk Management and Compliance
We will have frameworks for risk management and compliance.
We will abide by all applicable law and regulation and have an appropriate compliance framework in place.
We will maintain an appropriate risk management framework with systems and internal controls to identify and manage the risks we face.
We will have practices in place to limit, monitor, and control the risks related to Market trading activity.
We will have processes in place to independently review the effectiveness of and adherence to the risk management and compliance functions.
6. Credit and Counterparty Risk We will have adequate processes to manage counterparty credit risk exposure, including where appropriate, the use of appropriate netting and collateral arrangements, such as legally enforceable master netting agreements and credit support arrangements.
We will have processes to measure, monitor, report, and manage market risk in an accurate and timely way.
We will have independent processes in place to mark-to-market trading positions to measure the size of our profit and loss and the market risk arising from trading positions.
We will have business continuity plans (BCPs) in place that are appropriate to the nature, scale, and complexity of our business and that can be implemented quickly and effectively in the event of large-scale disasters, loss of access to significant trading platforms, settlement, or other critical services, or other market disruptions.
We will take prudent measures to manage and reduce Settlement Risks, including prompt resolution measures to minimise disruption to trading activities.
We will keep a timely, consistent, and accurate record of our market activity to facilitate appropriate levels of transparency and auditability and have processes in place designed to prevent unauthorised transactions.
We will perform “know-your-customer” (KYC) checks on our counterparties to ascertain that our transactions are not used to facilitate money laundering, terrorist financing, or other criminal activities.
We will have processes in place to identify and manage legal risks arising in relation to our market activities.
Confirmation & Settlement
We will establish consistency between our operating practices, documentation, and policies for managing credit and legal risk.
We will institute a robust framework for monitoring and managing capacity in both normal and peak conditions.
7. Office Environment
Energy saving policy
Encouraging the following:
envirnoment awareness, use of public transport, recycling in the workplace, flexibility with remote working and an aspiriation that staff are aware of their carbon footprint.