In 2010, our Group Control Room (a specialist compliance function which provides guidance on information controls and acts as a central clearing house for transaction-related conflicts of interest) re-launched Standard Chartered’s Personal Account Dealing Policy and Procedures and Group Conflicts of Interest Policy and Procedures, thereby further strengthening our global approach to identifying and managing actual or potential conflicts of interest. The re-launch was accompanied by a global roll-out of mandatory eLearning for all our Wholesale Banking employees, covering areas such as insider dealing, suspicious transaction reporting and inducements.
We also successfully integrated our Trade Surveillance team into our Group Control Room, providing joint oversight of potential trade anomalies. We made a significant effort to ensure a continued enhancement of our manual and automated trade surveillance capabilities in areas such as market conduct. These capabilities include enhanced monitoring of electronic communication.