Propose practices and procedures that head off breaches of the Code and Standards under Standard II, Integrity of Capital Markets

The core defence is an information barrier around anyone who may hold material nonpublic information: communication across it cleared by compliance, physical and systems separation, and documented enforcement. When the firm is brought over the wall on an issuer, compliance puts the name on a watch list or a restricted list, with a reach that depends on how far the information could travel in the firm, personal and proprietary trading in it gets closer review or is restricted, and staff brought over stay restricted until the information is public. Calls with expert networks should be screened by compliance. Against manipulation, surveillance should flag orders clustered near the close, especially at period-ends, and holdings should be priced by an independent source so managers cannot mark their own positions. Each control should be tied to the risk it closes.