Activity
Establish ethical values
Analyse internal environment ICS ERM
Organisation
Responsible
Senior Management
Input/Output
Input data
Code of conduct
Output data
Code of conduct
Requirements
Requirements (Basel II)
Board and senior management oversight
Requirements (SOX)
Section 306: Insider Trades During Pension Fund Black-Out Periods.
Section 304: Forfeiture of Certain Bonuses and Profits
Section 206: Conflicts of Interest.
Section 402: Enhanced Conflict of Interest Provisions
Section 405: Exemption
Section 802: Criminal penalties for altering documents
Section 203: Audit Partner Rotation.
Section 204: Auditor Reports to Audit Committees.
Section 906. Corporate responsibility for financial reports
Section 403: Disclosures Of Transactions Involving Management And Principal Stockholders.
Section 303: Improper Influence on Conduct of Audits
Requirements (MIFID)
Article 18 Conflicts of interest
Article 22 Conflicts of interest policy
Article 26 Inducements
Article 5 General organisational requirements
Article 21 Obligation to execute orders on terms most favourable to the client
Article 9 Persons who effectively direct the business
Article 21 Conflicts of interest potentially detrimental to a client
Article 23 Record of services or activities giving rise to detrimental conflict of interest