Conflict of interest policies must protect index integrity, control information flow and impose trading restrictions for affected personnel. Index providers must establish documented, implemented and enforced conflict of interest policies to protect index integrity by identifying, disclosing, managing, mitigating or avoiding conflicts; these policies must apply to oversight and operational staff, control information exchanges, require employee compliance with laws, protect confidential and material non public information, and specify protections for sensitive information along with trading restrictions and pre clearance requirements for personnel affected by pending index changes.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Conflict of interest policies must protect index integrity, control information flow and impose trading restrictions for affected personnel.
Index providers must establish documented, implemented and enforced conflict of interest policies to protect index integrity by identifying, disclosing, managing, mitigating or avoiding conflicts; these policies must apply to oversight and operational staff, control information exchanges, require employee compliance with laws, protect confidential and material non public information, and specify protections for sensitive information along with trading restrictions and pre clearance requirements for personnel affected by pending index changes.
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