Individual Conduct Rules

The below guidance helps employees to understand their obligations when complying with the conduct rules and the types of actions that could result in a breach of the rules. Staff are made aware that the guidance is not exhaustive and have continual access to personnel who can direct them on specific obligations and responsibilities.


Act with integrity – staff must not (or attempt to) mislead clients, colleagues, the Company or any associated regulator in any way or falsify, destroy, or cause the destruction of documents or information. All information must be accurate and a true representation of the facts and should have supporting evidence where risks are involved. Staff must pay due regard to the interests of the customer and must be aware of and report suspected breaches of the COCON rules with immediate effect.


Act with due care, skill and diligence – staff are made aware that this rule holds even more importance where activities might affect customers or the integrity of the financial system. Customers, the Company and regulators (where applicable), must be informed of any risks involved, as well as charges and/or penalties associated with a product or service. Any conflict of interest is to be disclosed at the start of a relationship/transaction and any advice given must be fully supported and be from an expert source with full understanding of the activities involved.


Managers understand that they must be knowledgeable about the business unit for which they are responsible and recognise that their role involves continual learning and development. Managers are monitored to ensure that they take full responsibility of their business area and that it is controlled effectively and complies with the relevant requirements and standards of the regulatory system. Effective and adequate oversight is mandatory, as are a full knowledge and understanding of the risks involved in their specific business area.


Be open & cooperative with all regulators – Where a person’s holds a position that makes them responsible for reporting matters to a regulator (i.e. FCA); they are expected to do so within the timeframes and deadlines set out in the FCA handbook. Such staff will be provided with training on how, where and when to report such matters and will be monitored to ensure that they comply.


Pay due regard to the interests of customers and treat them fairly – all staff are made aware of this rule and are provided with dedicated training on the TCF outcomes and how to treat customers fairly. This rule applies to all staff, whether they are customer facing or not, and ties in with one of the FCA’s main principles of business. Staff are made aware that they must always keep customers informed and that such provisions are accurate and are provided in clear detail. Customers are kept aware of any risks, charges, penalties and circumstances that may negatively affect them; and any advice given is based on an expert knowledge of the activity.


Observe proper standards of market conduct – the Company endeavours to comply with the relevant market codes and exchange rules and as such, staff can comply with this individual conduct rule. All staff with roles relevant to this rule are kept fully aware of the relevant market codes and exchange rules and are monitored on a continual basis for compliance.