7.5.1. Conditions for Personal Transactions

An Authorised Firm must establish and maintain adequate policies and procedures so as to ensure that:

• (a) an Employee does not undertake a Personal Transaction unless:

(i) the Authorised Firm has, in a written notice, drawn to the attention of the Employee the conditions upon which the Employee may undertake Personal Transactions and that the contents of such a notice are made a term of his contract of employment or services;

(ii) the Authorised Firm has given its written permission to that Employee for that transaction or to transactions generally in Investments of that kind; and

(iii) the transaction will not conflict with the Authorised Firm’s duties to its Clients;

• (b) it receives prompt notification or is otherwise aware of each Employee’s Personal Transactions; and
• (c) if an Employee’s Personal Transactions are conducted with the Authorised Firm, each Employee’s account must be clearly identified and distinguishable from other Clients’ accounts.

7.5.2. Content of written notice

The written notice in COB 7.5.1(a)(i) must make it explicit that, if an Employee is prohibited from undertaking a Personal Transaction, he must not, except in the proper course of his employment:

• (a) procure another Person to enter into such a Transaction; or
• (b) communicate any information or opinion to another Person if he knows, or ought to know, that the Person will as a result, enter into such a Transaction or procure some other Person to do so.Where an Authorised Firm has taken reasonable steps to ensure that an Employee will not be involved to any material extent in, or have access to information about, the Authorised Firm’s Regulated Activities, then the Authorised Firm need not comply with the requirements in COB 7.5.1 in respect of that Employee.