Institutional Investors such as endowments, foundations, pension funds, and insurance companies have an obligation to ensure that all facets of their business are compliant with both internal guidelines as well as financial services regulations; however, in today’s complex regulatory environment, especially as limited partners increasingly make direct investments, institutions should be diligent in mitigating all risks related to employee conflicts of interest and material non-public information (MNPI).
ComplySci helps Institutional Investors map their unique Employee Code of Ethics Policies to preclearance and approval workflows, mitigating risks related to various employee conflicts of interest.
Identify Market Abuse
Personal Trade Monitoring
Section 10(b) and Rule 10b-5 of the SEC 1934 Act prohibit the purchase or sale of securities with the use of MNPI. In addition, institutions that fail to prevent insider trading may be subject to civil penalties under Section 21A of the 1934 Act. As a result, many Institutional Investors incorporate the maintenance of a restricted securities list as well as a preclearance and/or disclosure policy for personal trading.
ComplySci automates preclearance and disclosure workflows, so your firm can maintain an audit trail of employee activities. Additionally, the ComplySci platform ingests data directly from more than 200 brokers to help insider trading analytics including post-trade testing.
CONDUCT HONEST BUSINESS
Gifts and Entertainment Approval Workflow
Because Institutional Investors often invest with fund managers, the receipt of gifts by the firm could be perceived as an attempt to influence deals. For public pensions, the risk is even greater as gifts to political candidates with influence over state pension funds could be interpreted as Pay-to-Play violations. ComplySci’s preclearance and disclosure workflow maps to your firm’s G&E policy, so that gifts that fall outside a certain threshold can be automatically approved, denied, or sent to Compliance for review.
Strengthen Your Code of Ethics
Certifications and Attestations
Many Institutional Investors require their board members or investment personnel to annually certify to compliance with the firm’s Code of Ethics policy and training. ComplySci automates the certification workflow, reminding employees to certify while creating a full audit trail of certification records.