Submitter Code of Conduct as well as on relevant regulation (including in relation to benchmarks and market abuse). Conflicts of interest 8.1 Participants should maintain and operate effective organisational and administrative controls to enable them to identify and manage conflicts of interest that may arise from the Benchmark process including: policies to manage conflicts arising between the Participant’s role as a submitter to the Benchmark and its other business areas including transacting with or for clients and counterparties in products which reference the Benchmark; submission of data from front office functions must be subject to adequate internal oversight and verification procedures; policies relating to the handing of client and proprietary orders; the physical separation of employees and reporting lines where appropriate; the consideration of how to identify, disclose, manage, mitigate and existing or potential incentives to manipulate or otherwise influence data inputs (whether or not in order to influence the Benchmark) including through appropriate remuneration policies and effectively addressing conflicts between the Participant’s submission activities and any other business of the Participant or of any of its affiliates or any of their respective clients or customers; and policies to prevent behaviour that threatens the integrity of the Benchmark. Whistleblowing 9.1 Participants should maintain a whistleblowing policy so that employees have a means to anonymously raise concerns regarding unlawful or inappropriate practices related to the Benchmark determination process.
Submitter Code of Conduct as well as on relevant regulation (including in relation to benchmarks and market abuse). Conflicts of interest 8.1 Participants should maintain and operate effective organisational and administrative controls to enable them to identify and manage conflicts of interest that may arise from the Benchmark process including: policies to manage conflicts arising between the Participant’s role as a submitter to the Benchmark and its other business areas including transacting with or for clients and counterparties in products which reference the Benchmark; submission of data from front office functions must be subject to adequate internal oversight and verification procedures; policies relating to the handing of client and proprietary orders; the physical separation of employees and reporting lines where appropriate; the consideration of how to identify, disclose, manage, mitigate and existing or potential incentives to manipulate or otherwise influence data inputs (whether or not in order to influence the Benchmark) including through appropriate remuneration policies and effectively addressing conflicts between the Participant’s submission activities and any other business of the Participant or of any of its affiliates or any of their respective clients or customers; and policies to prevent behaviour that threatens the integrity of the Benchmark. Whistleblowing 9.1 Participants should maintain a whistleblowing policy so that employees have a means to anonymously raise concerns regarding unlawful or inappropriate practices related to the Benchmark determination process.
Comdaq%20Metals%20Ltd%20Submitter%20Code%20of%20Conduct.docx