94. The management body should have clear and documented policies for how these standards should be …

The management body should have clear and documented policies for how these standards should be met. These policies should:

a. remind staff that all the investment firm ’ s activities should be conducted in compliance with the applicable law and with the investment firm ’s corporate values ;
b. promote risk awareness through a strong risk culture in line with Section 9 of the guidelines , conveying the management body’s expectation that activities will not go beyond the defined risk appetite and limits defined by the investment firm and the respective responsibilities of staff;
c. set out principles on and provide examples of acceptable and unacceptable behaviours linked in particular to financial misreporting and misconduct, economic and financial crime including but not limited to fraud, money laundering and terrorist financing (ML/TF), anti-trust practices, financial sanctions, bribery and corruption, market manipulation, mis-selling and other violations of consumer protection laws, tax offences, whether committed directly or indirectly, including through unlawful or banned dividend arbitrage schemes;
d. clarify that in addition to complying with legal and regulatory requirements and internal policies, staff are expected to conduct themselves with honesty and integrity and perform their duties with due skill, care and diligence; and
e. ensure that staff are aware of the potential internal and external disciplinary actions, legal actions and sanctions that may follow misconduct and unacceptable behaviours.

1. Overview

Summary	Regulation

Requirements
Source	Requirement

Standards
Source	Requirement