Name: Guardrails, Not Roadblocks: Employee Conflicts of Interest Monitoring in UK & EU Private Markets
Uploaded: 2025-10-22T11:20:17.469Z
Duration: 48 min 3 s
Description: Guardrails, Not Roadblocks: Employee Conflicts of Interest Monitoring in UK & EU Private Markets

Transcript for "Guardrails, Not Roadblocks: Employee Conflicts of Interest Monitoring in UK & EU Private Markets": Hi, everyone, and welcome to our webinar, guardrails not roadblocks, employee conflicts of interest in The UK and EU private markets. I can see a couple of people just trickling through. So we'll give it a couple of seconds, just to let them join, and then we'll get kick started. So thanks so much for everyone that's that's just joined. We've got a really great lineup of speakers today who'll be sharing some practical insights and their expertise on the current global regulatory landscape, conflicts of interest monitoring, and also giving examples into how you can improve your processes across your firm. A good place to start though would be for us to introduce our speakers. So I'm Mariana, and I'll be your host and your moderator for today. I've partnered with firms across EMEA helping them to transform their GRC programs. For those of you who don't know Comply, we're a global compliance solution provider focused on providing financial firms with compliance automation across their employee conflicts of interest and also their personal account dealing as well, as well as firm wide compliance in one complete solution. So I'll hand over to our amazing panel, to introduce themselves. But, Michael, if you want to start. Sir, I'm Michael Rasmussen. I'm an analyst. My job is research. I research what are the challenges companies like yours face in the context of governance, risk management, and compliance, and how do they go about solving that with strategy, process, and technology. I have my accent is American, and I live in The United States, but I am far busier across The United Kingdom and the rest of Europe than I am in The US. So interact with a variety of organizations, particularly financial services organizations on these topics and so much more in risk and compliance. Perfect. Thank you. And if we go to Alex. Hi, everyone. I'm Alex. I'm a director at Optima Partners. We're a global regulatory consultancy firm. I specialize in providing compliance advice and support services to firms in the private market, so very topical for today's webinar. So I provide a range of compliance support services to firms that are private equity, private credit, and venture capital firms. Prior to Optima, I've worked in house, investment managers and private equity firms and have a legal background. Thank you. And Jacqui. And hi, everyone. So I'm Jacqueline Morcombe. I am the SVP of EMEA here at Comply. I lead our sort of international business as well as over the last twenty or so years, I've partnered with financial institutions that are undergoing technology transformation predominantly in the world of credit, and compliance. So really excited for today's conversations and look forward to it. Perfect. Thank you. And a huge thank you to all of our panelists for joining us for today's discussion. Everyone's got such a range, and depth of experience, so I'm really excited to hearing all of your insights. As I'm sure you're all aware, private markets have grown into a cornerstone of global finance around 15 and a half trillion dollars worldwide and roughly 1,200,000,000,000.0 here in The UK. But unlike public markets, much of what happens in private markets still sits in the shadows, and that's why the FCA have really been ramping up its focus to improve data, value transparency, and oversight to help build more sustainable growth and maintain market integrity. And it's not just here in The UK. Across Europe, regulators are joining forces on the first ever stress test for non bank financial intermediaries such as private equity, hedge funds, and insurers and pension funds. A move that can have major implications for liquidity resilience, but also conduct and compliance expectations. Hence, our discussion today. So as scrutiny continues to increase, firms are under more pressure than ever to make sure that the fundamentals, things like personal account dealing, conflicts of interest, and insider information are really watertight. Just as a bit of housekeeping for today, please pop any questions into the q r q and a. Our team are backstage monitoring them, and we'll follow-up with this webinar with an FAQ document addressing any questions that we get. And we'll also allow time for a little bit of a quick quick sneak peek into our Comply solution as well. I guess, Alex, a good place to start. I've touched on the increased scrutiny from the FCA and other regulators. But would you be able to give a little bit of an overview of the current regulatory landscape and why this is such an important topic for firms today? Thanks, Mariana. So as you touched upon, there's just been a real growth in private market assets in The UK and in Europe, but also globally. So I think private markets asset under management has tripled in the last decade in The UK, for example. And on top of that, we've also had a broader range of investors having access to private market assets, and that's via initiatives from the FCA and European regulators to launch these LTIF type vehicles that allow retail access to private market assets and through evergreen fund structures as well, which basically allow these funds to invest in private market assets but also have liquidity and redemptions for investors. And so, really, the regulators are concerned now around the fact that these markets have historically been more opaque. There's been less transparency. And we can see that with the FCA, for example, the last couple of years, there's been a lot of fact finding education for the FCA, and they've done a lot of thematic reviews in the space. So over the last couple of years, we've seen the FCA do a thematic review on CLOs, so so focusing on private credit. We've seen them do thematic reviews on handling and management of inside information. Recently, we've had the private markets valuation survey. And most recently, there's gonna be one focused specifically on conflicts of interest. So So that's gonna be looking at employee conflicts of interest, but also fund level conflicts of interest. So, really, the concerns are around sort of management of inside information, conflicts management, and valuations in this space. Perfect. Thank you, Alex. And it's it's really clear to see that there is that huge increase, as you mentioned, not just across, employee conflicts of interest, but also firm conflicts of interest, managing insider information, and market abuse is really high in the regulators, agenda. I guess, obviously, different firms, we need to ensure that they've got core, you know, long standing expectations around Maurer and really making sure that these are watertight. From your experience, Alex, what do you think best practice looks like from firms, and where would you really recommend that they start? So I really expect firms to start with a risk assessment. So in order to have sort of a robust compliance framework in place around personal account dealing and handling inside information, really a risk assessment where a firm can really map out their business model against the FCA rules and requirements to really identify those risks for their business. And that's even more important to firms in the private markets where, for example, the market of these rules might not directly apply, but they've got to think about its conduct requirements and conflicts of interest more. Then I would expect firms to be building out proportionate tailored policies and procedures, kind of guardrails for employees, And then that should be backed up by tailored training, really, again, focused on the specific risks for the business and private markets, and then backed up by effective systems and controls. And that's where a system such as a staff compliance system could be really useful because you want to be able to oversee and monitor employee personal account dealing, gifts and entertainment, outside business interests. You also want to be having good hygiene around the management of restricted lists, insider lists, watch lists, and then also thinking about controls around the flows of inside information and confidential information. So that should mean having robust wall crossing procedures, market sounding procedures, thinking about audit trails and folder security so that firm so employees are not receiving inside information except on a need to know basis. And then finally, I'd expect a good culture around compliance breaches, so consequences for breaches, and then also holistic monitoring on the compliance front as well. So looking at all the various compliance risks and monitoring to feed into that robust best practice framework. Yeah. Definitely. I think it's it's very important to have all of the fundamentals in place. And as you said, starting from, that risk assessment and looking at your controls and then how that can then feed into the rest of your compliance program. Are there any common red flags that you see when within firms, when they're initially starting out? Or I would say red flag wise. I mean, if I was looking at, you know, personal account dealing, for example, I mean, if you have very low volumes of personal account dealing at a firm, I think for me, that could be a bit of a red flag because it could signal that, potentially, staff are not understanding the policies and procedures and potentially are not disclosing all their personal account dealing or all their broker accounts. I'd also say if you get very high volumes of personal account dealing, that could be a bit of a red flag as well because it could signal, okay, our staff adhering to the pretrade approval windows Mhmm. Holding periods, you know, our staff distracted from their day drops. And then, also, I typically would look at the breaches register to also spot red flags because any extreme, if you have a lot of breaches, say, multiple breaches around personal account dealing, you know, that could be symptomatic of the fact that a firm doesn't have enough fight in terms of consequences for breaches and perhaps not enough senior manager kind of buy in or leading by example. And then no breaches as well could be a bit of a red flag because it's maybe that the compliance team do not have sufficient oversight and monitoring over staff compliance matters. Or perhaps, potentially, compliance are kind of being encouraged to kind of brush things under the carpet or not follow-up on breaches and report them effectively. And I think just to add, sort of one act anecdote around, what Alex is saying around the the trade volumes. I mean, we we've dealt with a asset manager who was they had about a thousand employees, and they had told us, prior to implementing our software, that they had about 200 PA dealings, a year Mhmm. Across their entire client base. And that turned out, to not be the reality. And it was a case of, the employees not, as Alex said, not truly understanding, the policies in place, but also not, declaring and sort of pre clearing some of the that training activity. And by putting a robust solution in place, it actually increased the sort of the the culture of compliance within the firm and the the employees' confidence or or belief that, you know, the stealings may, may be caught out and that there were there were policies in place and sort of systems in place that actually took, took control of this versus doing a a manual process where the sort of the barrier to adoption is high, and you can't have a compliance program without, an adoption element of it. If the employees don't don't adopt it, you're you're kind of stuck. But also just knowing that, yeah, things are being truly looked at versus just sort of going into the the sort of ether of email, around that. I would also say I know we talk about red flags, but what we find with compliant, what we would typically say is by the time you're looking at red flags, it's it's already a little late. And obviously, best late than never. But really, people should be looking out for sort of the amber flags or even better taking a more proactive approach, which is what the the FCA and regulators do look more favorably upon is is a more proactive approach rather than sort of now you're facing an SEC exam, for example, as a trigger that we often see or you've undergone an audit, and there are all these issues in in place. And so, you know, rather than the fire drill and your compliance individuals, you're extremely busy. You work in a very fast paced environment, you know, having to undergo sort of a transformational when when firms are adopting our technology. We don't like to do it in a fire drill scenario. We like to do it where it's sort of thought out and planned and you're not, you know, up against the wall on some of these these items. And so I'd say, look at your your amber flags and, you know, have have awareness that you can't you can't, control what you're not monitoring or tracking. And Alex sort of highlighted some of those those red flags around, you know, looking at your breaches. Too many, too little. PA dealings. Too many, too little. Those are all sort of indicators of things that you should, pay closer attention to. Yeah. Definitely. It's it's very important. And as you said, Jacqueline, it's it's something that we come up across, you know, a lot. And as Alex, you mentioned where, that compliance culture is really important and it's, you know, are there enough controls in place? Do your employees actually understand the controls? And are they actually being implemented as well with things like your policies? I think that leads us really nicely on to actually discussing and talking about compliance culture. As we discussed, there's such an importance on compliance coach, compliance teams to actually implement the controls, but also a lot of compliance teams want to manage the relationship with their employees as well. And often when I'm speaking with compliance officers, there's a culture of almost wanting to trust their employees, but also looking to strengthen the controls and the governance and also how they could potentially get more from a compliance standpoint as well. I guess, Michael, a question for you is, how do you think firms actually balance the culture of trust with stronger control and and governance? And is that something that that you've particularly come across across either UK firms or I know that you do a lot across the EU as well. Oh, I think you're muted. Sorry, Michael. Sorry. I sneezed earlier. I'm realizing I wasn't on mute. But, to me, to sum up a culture of trust, to me, I would summarize it in the words of my favorite, fictional premier league coach and philosopher Ted Lasso, that doing the right thing is never the wrong thing. At the end of the day, to me, this culture of trust in dealing with everything that we're talking about here today from personal account dealing and insider information to market abuse and that and how that goes to the compliance culture, it's all about the integrity of the organization. If I can rebrand the chief ethics and compliance officer, I would call this in the this individual the chief integrity officer that's really the bastion of integrity that, what we commit to from our compliance and regulatory obligations to to our values or ethics that we live by. And and so to me, that that's the firm that that that's the the the the firm message organizations need to have is that this isn't just about meeting a regulatory requirement. This is about doing the right thing. This is about the integrity of the organization, and and that's something we value. And and and a lot of this gets codified in policies. You know, when we're dealing with personal account dealing that we're just discussing, organizations need to have clear policies defining the restricted instruments and blackout periods, and with structured workflows, for, like, pre clearance workflows that are automated and auditable to reduce manual burdens and the all the time it takes to do this in manual processes. And with and, of course, you have the ongoing surveillance and and monitoring of this as well that's required. And and there's robust controls that need to be put in place as well for insider information to keep all that information current and up to date and, in the regular training, so employees can recognize what constitutes material non public information. All this is absolutely critical as we move into this. You know, firms should treat themes and and, some of the things I'm talking about is what we just were talking about, personal account dealing. But firms should treat compliance, whether it's personal account dealing, insider controls, and and in general, just market abuse, as living systems, not static documents to keep pace with the, the complexity and regulatory change of the modern financial services organization. But but culture is the first line of defense as you're asking me about culture. You know, a tick box approach to compliance fails under regulatory stress tests. It it it it it we need to be able to embed what it's talking about, that culture of integrity. Doing the right thing is never the wrong thing. You know, that right thing, that culture of integrity and accountability, With that culture of integrity and accountability reduces risks of conflicts of interest, insider dealing, and reputational damage. You know, further to this culture, you have practical enablers where you have senior management, talking about this with the tone at the top, but then you have the melody in the middle, that middle management, and the beat at the bottom, the the edge of the organization that are all critical in defining this culture. The tone at the top, the melody in the middle, and the beat at the bottom, to use sort of a a musical theme to the the three levels there. And and we need all three of those to, which is really integral to business success in this culture of integrity that I'm talking about. Clear escalation channels need to be in place for employees to raise conflicts or potential misconduct, and, of course, integration of compliance into performance reviews, not just HR audit silos in those reviews. And and so, you know, the FCA's focus is clear to me. Conflicts of interest are not isolated risks. They tie directly into broader market abuse and conduct oversight, and firms must see that things like conflict of interest monitoring as part of their holistic market abuse prevention. And again, to me, this is all embraced in a culture where the organization is trying to become, a strong culture of integrity, not just compliance check boxes. Doing something you said there, Michael, and Alex mentioned this earlier, is that ensuring the the education, and folks that are actually aware of items. So it's not just good enough to email a lot or or drop your sort of policies and procedures or code of ethics into a a share SharePoint folder and expect people to go and self serve. But it's also about living and breathing it and making it, you know, that that barrier to adoption is significantly reduced so that folks that are not necessarily bad actors, but just working without knowledge, are kept informed. And, also, you know, you have the right, parameters in place should anything sort of go the wrong way. And so it's, you know, even where folks are working with the best intentions and they have high integrity, you know, human beings make mistakes, and that's where you need to have that ongoing education enforcement, belt and suspenders kind of approach. Yeah. Definitely. And it's I think that education point is is something that that's really key, to build now a a really successful compliance culture. Alex, how can a strong compliance culture actually reduce market abuse risk as well? I don't know if there's anything additional that that you would want to add to that. Yeah. So I think it is the fact that having a strong compliance culture kind of breeds that tentative culture. So it's a place that, you know, employees are not afraid to kind of raise their hands, come to compliance with questions, raise issues early. It's that sort of open collaborative culture, and it's culture where kind of staff at the front office will take ownership of the risks. And as you talked about this whole educational piece, like, where they really understand the risks, they take ownership for them. And it means that there would you know, there's no firefighting. You're not trying to address issues after they've happened, which is, like, vitally important for market abuse where, really, there's a zero tolerance approach by regulators. And we see that the regulators really focus on strong compliance cultures. So the FCA has talked about culture a lot over the last few years in various discussion papers, consultations, speeches. And we see a lot in enforcement trends, like looking at final notices, that culture always plays a key part in firms that are ending up in a situation where they're kind of getting enforcement action intervention from the FCA. It often starts with a poor compliance culture. Yeah. That that's very interesting. And I guess, Michael, probably back to you on another one. I just wondered if there was any differences or similarities in approach that you see in compliance culture between, for example, UK firms and EU firms and potentially the differences, or similarities with, the approach to the regulators as well? I I mean, I find that it it's, fairly similar between UK and EU from my perspective. I mean, because a lot of it's, you know, principles and outcome based, approach where The US is so much more compliance checkbox. You know, what started off with the FSA, gosh, twenty years ago with principles and outcome based regulation moved over to the EU, and is reflecting a lot of the EU policy. So to me, there's a much stronger risk based approach to broad compliance areas in financial services than what you see in The US, which is tends to be more, check tick box based approach. Yeah. That that's definitely interesting in terms of, you know, the tick based approach, compared to, that proactive approach and how those differentiators are there as well. I guess we've spoken a lot about, improving controls, how this can then, improve your compliance culture and the problems that can occur if you don't have, one, a strong compliance culture, two, that education piece, that is in place as well. And then I guess the additional part, that has come up and and, Alex, I think you mentioned it at the start as well is those employee compliance solutions and actually, what you could possibly be using, from a technology standpoint as well. But I guess, Michael, you've got a lot of experience with, working with firms and looking at their different GRC approaches. But when at and at what point do you think the firm should be looking at automation? Certain firm size, for example? I mean, to me, from my perspective, we're all using technology. And so in this context, the whether you're using stone tablets and chisels, you're stuck in the stone ages, that's technology. If you're using pen and paper, that's technology. If you're using documents, spreadsheets, emails, that's technology. If you're using Comply, well, that that's much better technology. And and to me, it doesn't matter about size. The small firms, the the they struggle because they have to wear so many hats and there's so much going on. So all the more reason for technology to provide that structure and automation in this area. Of course, larger firms have a lot of complexity to their operations and things, and they also need technology. So so we're all using technology. The question comes down to more, are we using the right technology and and what, is the appropriate technology, for us, over the me if I was speaking on behalf of a firm. You know? So to me, this is where technology has the potential to transform compliance oversight. Instead of compliance being a drag on the business, the right technology, which I would argue would be Comply, you know, or something similar to Comply, delivers smart automation that can actually become a growth enabler for the smaller organization to the large organization. The the time to look at automation isn't to me is not Sunday or only when the firm becomes large. It's it's when, you know, your headcount starts growing and compliance oversight no longer scales manually with manual technology processes like documents, spreadsheets, and emails. And and to me, that's a lot of organizations. Another thing to consider is investor due diligence begins probing how conflicts of interest are monitored. And so, having that structured, accountability and auditable, workflows and themes and that that system of record is absolutely critical with investor due diligence, begins probing. And regulators signal higher expectations as we're seeing right now in both UK and EU. So a good rule of thumb is, you know, if I need to really answer the question directly, is if your compliance team spends more time chasing spreadsheets than analyzing risk, you've already reached the point where automation is necessary. We can't I mean, I I one firm that I talked to did internal study and found that 80% of their staff time was actually chasing documents, spreadsheets, and emails, not managing compliance risk. You know, that's wasted time. I mean, I didn't go through college and a law degree to, like, sit there and chase people filling out spreadsheets and word documents. I mean, not not at all. I I wanna help improve compliance and things and and technology takes all that un that 80% of, like, wasted time, and and allows me to focus on compliance risks and improve the integrity of the organization. You know, some of the benefits of automation from my perspective is speed and efficiency or pre pre clearance requests, that once took days can be processed in second. It's that accuracy of the information and that robust system of record where automated, you know, restricted list checks reduce human error and cash potential breaches early. You have that auditability in that system of record. You know, every action should be time stamped and logged, which is gold in an FCA review or an investor audit, you know, showing that system of record of activities with that date and that time stamp, on what happened, when it happened. That's critically important. You know, technology provides integration where smart compliance platforms like Comply, plug into, you know, different brokerage fees, HR systems, and trading desks, eliminating duplication and manual efforts. You've got front office experience, you know, that instead of fighting the process, employees engage with a clean, intuitive workflow. They Comply because it's easy to Comply. That's critically important. So to me, technology becomes the compliance enabler. You know, technology reframes compliance from being a roadblock to being an accelerator. When front office teams see compliance processes that are smooth, quick, fair, they are more likely to cooperate reinforcing the very culture we discussed earlier, that culture of integrity. And and so those are all things to consider. Yeah. I support everything Michael Michael said. He can come work for Comply when whenever he likes. But it I mean, I think that that technology has fundamentally changed. Right? Like, so fifteen years ago, you had legacy oh, actually, some vendors even more recently. But legacy on prem technology meant that the barrier to adoption was extremely high, and we've come a long way. So now you have true SaaS solutions, and so you get firms that are you know we've got a client that adopted our software very recently. It's a a start up hedge fund in APAC. They're they're tiny. They're they're planning for their future. And they're using the same, underlying platform that a a global investment bank is using. And that it that that hurdle and that barrier to adoption, it has really gone away. And so you don't have to use the the piece of stone and the, you know, your pestle and mortar and all that good stuff because there are options out there, and the market's moving quite quickly with that. So, you know, I think I agree with what what Michael says around, you know, you've gotta be proportionate and you gotta look at when it makes sense. And and, ultimately, you know, compliance folks are typically, you know, really smart, capable of so much more than paper pushing, and that's not what what people want to be doing with their time. And so it's sort of you know, you get an employee satisfaction benefit out of there and the the front office sort of hurdles and the friction that you get between, compliance and the sort of their their monitored employees or their their customers, so to speak, is all reduced when you make it easy to adopt, mobile friendly, and so on. I mean, yes, you check you get, you know, all the check boxes that you need to do and being able to evidence, you know, your your policies and procedures and enforcement of that to your regulators. You meet your investor, due diligence. That is, you know, that's increasingly being automated, and the question is no longer, you know, if it you know, what do you use or how do you do it? But it's how do you automate. It's very specific. It's no longer do you have a system for or provide us with. It's how do you automate and there's an expectation that you're using something market leading. So, you know, there's there's lots of reasons to sort of embrace technology earlier on, and the the barrier to adoption has really scaled right down, for financial institutions nowadays. Yeah. Definitely. And I think as as Michael touched on, it's almost allowing technology to be that enabler for compliance teams rather than actually restricting that compliance function. Alex, have you had much experience in, firms that you've worked in with, you know, maybe having a manual based approach and moving into, a automated approach and, you know, the journey that they went on and how it benefited, any clients that you've worked on for worked with, for example. Yeah. I mean, I have a lot of clients where they've made that transition from kind of a manual spreadsheet approach, which is really difficult for audit trails, consistency of information. So, really, the transition to a staff compliance system, I always kind of recommend. I think it's very valuable. I think the more you can automate, you know, one, you're reducing your risk. You know, I think the key thing with these systems is also just, like, automatic blocking for the restricted list or the watch list. Really valuable, you know, remove, like, manual kind of checks where there's, like, room for error. And then, also, it's just having everything consolidated. So we talked you know, Jeff and you talked a little bit about, you know, investor due diligence. And a lot of my clients as well will have consultants come on-site and do due diligence as well, and they want to see up to date registers. They want to understand the systems you're using. They want to see automation. They want, you know, they want to understand what regtech you're using. So, you know, I think it's really valuable to kind of use one of these staff compliance systems where you have that order, record keeping. And then also, as we touched upon before, it's just very time consuming and burdensome for compliance teams to be keeping track of all these employ employee conduct matters. You know, personal account dealing, you know, you've got preclearance requests, broker statements, reconciliations, monitoring, then you've got your g and e. You've got your outside business interest, maybe political contributions, attestations. So just having a system where everything can be consolidated and in one place is just really valuable, and it really helps with compliance monitoring as well. You know, the FCA has talked a lot about holistic monitoring, where you're looking at lots of different information sources. And I just think having as much as possible in a system can really then enhance that monitoring and make sure that you're meeting regulatory expectations around that. Yeah. Definitely. I think something that we haven't touched on, but I've noticed a real trend, even over the past twelve months, and are maturing within, within the buy side or within asset managers around to that that holistic data frameworks. And Michael spoke about the, the sort of the levers for growth. And and what we're finding is that, there there's less appetite for data in silos. There's more desire, not just for sort of siloed reporting, but actually how do I get all of my data around and into a data lake and report across the business? So we we're finding more and more. Our customers are asking us for integration to make life easier, so APIs for GNE or HR systems and so on. But, actually, how do I extract out and add that information to to a wider set of data. And then we can do sort of firm wide data insights, reporting, and so on. So, you know, you have to really kinda start with a a dataset, then you need data that is extractable in a in a raw format and complete. And then you can use that to build out, you know, business insights as a financial institution. And I think, you know, there there are much broader benefits even outside of the compliance function, when you really get to that data first approach. Mhmm. Yeah. Definitely. And I guess with that, one of the the questions, and, I'm not sure who'd be best placed to to answer it, but one of the questions, or one of the concerns, I guess, that often comes up when people are thinking about moving from a manual based approach into an automated approach or even moving from a legacy system, into a new system is actually around that change management piece as well. Has anyone had any experience or any advice to firms on how actually, you know, they can implement a new system, tighten up their governance and controls, and actually manage that that change management piece internally. I can take a first pass, but I'm very keen to hear Alex's feedback because I know Optima works with a number of our firms as well. So you folks see see and hear a lot. But, you know, we we've seen some firms that are actually starting out building, their compliance frameworks and their compliance program, and they they're actually either using the implementation of our technology while they're building out, their compliance program and rolling it out. And others are also using it as an opportunity to change, and and make either centralized all of their policies and procedures. We're seeing firms and actually a trend more and more is setting up central compliance functions where you have things like PA dealing, in one location, often London, interestingly, because it spans across EMEA and APAC sorry. US and and APAC time zones. While things like, GNE or outside business interests remains within region and being able to sort of have that, sort of local and global kind of approach, which is is pretty good. But but what is we find pretty critical, to that change and that adoption is whatever you do, it just needs to be easy. Like, if you make something super difficult for people, then the people don't like change. I don't like change, and I work in technology. But don't I'm still using the old Outlook. I refuse to change. So, you know, if it was easier, I would say Microsoft, I would probably have made that change. And so you've got to make life easy for people because compliance isn't a, you know, your trading desks, day job. And so you've got to make that barrier to adoption, reduce that friction, and just make it seamless and and improved, which is which is critical. And there's lots more, but I'll hand over to to Alex or Michael to sort of give their perspective. No. I mean, I agree with you. I think, you know, generally making the process as pain free as possible is great. And I think, ultimately, if you're moving from a lot of, like, fragmented manual processes to a consolidated staff system, it's usually beneficial for staff. And I think, you know, provided you have the right training and education, like, normally, it's quite a seamless process. And, you know, it means that, you know, staff are submitting, say, their customer count dealing, g and e. They have a consistent form. You know, they have their quarterly attestations. The system shoots out regular reminders. You know, ultimately, it usually is beneficial for staff. It gives them those clear guardrails how to kind of, like, manage all their staff conduct items and conflict of interest items. So Yep. I think, generally speaking, you know, that's what I've seen. You know, I've not seen it being painful. I see, generally, it's, like, a beneficial change for a business. And then also things like having broker fees in these systems is just great because then, you know, you can connect your broker feeds. Everything's pulled in automatically through the system. It saves all these manual broker statements. It saves endless emails between compliance and the business. So generally speaking, I just think the move is usually, like, a beneficial one for the front office and staff. And I think it the key thing is just education and training around the system at the beginning. It's been stated by and it well, attributed to both Schumacher and Einstein, so I don't know who originally said it. But the the statement, any intelligent fool can make things bigger, more complex, and more violent. It takes a touch of genius and a lot of courage to move in the opposite direction. You know, simplicity is extremely important, being able to engage, the the end user for compliance solutions to make them wanna use it and and not be a burden on them and and so however we can simplify that engagement is absolutely critical, for technology in that context. The the other interesting aspect and and I just love quotes and references, but the physicist, Freidjak Chopra, stated, the more we study the major problems of our time, the more we come to realize that they cannot be understood in isolation. They are systemic problems which means that they are interconnected and interdependent. And that even though he's talking about biological ecosystems at the time of that quote, it it applies to compliance in the financial services organization today is that, you know, we need to have that visibility across policies, across training, across disclosures, you know, across what was reported. All this is absolutely critical to be able to to see the big picture of compliance and to aim for that measurement of integrity. And technology delivers that. Yeah. Definitely. And I guess from everything that that everyone said, it it links back into, that culture of compliance, the relationship that you have, and making it as easy as possible for, your front office staff, really embedding in your policies, and making it easy for them to actually then follow them. And then, again, that's gonna reduce, any risk and tighten that, governance and controls with inside of your business. I just wanna make sure that we've got, enough time, to give a quick sneak peek, into the Comply solution. But I don't know if anyone else had anything else, that they wanted to mention or that they thought was particularly important or something that we haven't covered, from today's session that you thought would be beneficial to cover at all. No. Anything I thought would be useful to add is around the fact that, you know, these systems are often really beneficial as well for management information and reporting. You know, we've seen again, looking at enforcement trends, like poor management information, poor oversight by committees and boards is, like, a real key thing for regulators. So I think being able to really quickly run data and stats using these systems is really valuable. And then also just being able to run the registers reports, having that audit trail, again, I just think is really important for regulators. So I think that's another aspect that I just wanted to touch upon as well. Yeah. Definitely. And I think that reporting side is is very important as well because if you are running a manual based approach and it's taking you time to actually build up these reports, that report is actually out of date the time that you've actually collated it and then put it together. Whereas the reports that you can take out of the system are instant, up to date, and you're gonna have all of the relevant information in there. So, yeah, I think, definitely, Alex, that's a very good, addition and something that's very important. I guess, quickly, I just wanted to mention our comply connect event. We're hosting an event in November. It's a networking event for our compliance community. You can scan the QR code that's on the screen if you'd like to join us. It will take you through to the registration page, and you can view our agenda there. I believe both Alex and Michael, will be joining us on the day as well, which will be very exciting. But we'll also follow-up with a link, that you can use to register as well. And then finally, just before I hand over to my colleague, Ashok, who's our Comply Solutions engineer, he'll be running you through and giving you a little bit of a sneak peek into the Comply Solution and some of the elements that we've touched on, this this morning. And I just also wanted to give a really huge thank you to our panelists for joining us today. Michael, Alex, and Jackie, your expertise has been very greatly appreciated. I really hope everyone joined the webinar. If there are any additional follow-up questions, please feel free to email me or you can connect with me on LinkedIn. But, otherwise, I'll hand you over to Ashok for a quick sneak peek into Comply, and how we can help with some of your conflicts of interest monitoring. But thank you all so much. Thank you. Thank you. Thanks, Mariana. So moving from theory to practice, happy to showcase a few highlights of the Comply platform and how we can help firms operationalize some of the principles that's being discussed today. So let me just quickly go ahead and share my screen. And as that comes up, Comply has been primarily built to streamline code of ethics policies and employee monitoring processes through one centralized automated platform. And Comply provides compliance and supervisory teams a customizable real time dashboard view of trends, open tasks, policy violations, certifications, enabling both proactive and timely actions to ensure policies are being followed. When it comes to identifying suspicious trading activity, the platform helps flag common indicators to unusual trading activity or volumes, deviation from historical behavior, and any sudden interest in specific assets or industries. And all of these patterns can easily be detected and analyzed through this compliance dashboard. So the platform does feature a modern and intuitive interface, making it easy for your compliance team to navigate the system, visualize the data, and then take action swiftly. Comply also allows, configuration of, different types of, rules and workflows against your company policies. And here are some examples of the common types of trade rules that we see implemented by our clients. And these can be built as simple or as complex as you like depending on the nature of your firm's business and the potential risks that you could ope that you could be open to around insider trading and other market abuse issues. This includes the ability, to host your restricted list within Comply or directly integrate lists from other internal or third party systems and set rules to automatically deny any trades against those lists. Do bear in mind, post trade rules are also processed to ensure trade violations are flagged immediately. And as you can see across the top, pre clearance rules can be built into any of the workflows that are being managed in Comply. So what is the experience like from the employee's point of view? I'm gonna use the emulation feature here just to showcase that. So once templates, workflows, and rules against your firm's policies are built out, employees have the ability to log in to Comply and easily submit a pre clearance request for any of the different activity types, whether that be a personal trade, whether it's listed or not listed, gift entertainment, you know, business conflicts or a personal conflict that they may wish to disclose. Below are your control room activity types that can be leveraged to disclose inside information exposed through any business activity type, reaching out to expert networks, internal meetings, and so on. To give, one quick example of how someone can go about pre clearing, personal trade. They would log in and simply click the trade icon. That's gonna come up to you with a customizable form with a set of instructions that's obviously gonna be configurable. And as I drop down, there's gonna be some basic information that is requested to your employees, including your transaction type, quantity of shares, and tagging the associated security against one that identifies. So in this case, if I was to search against Tesla, there'll be a drop down where the system is going to identify if there are any current holdings in the system, answer any custom questions, drag and drop any files, and then submit. And once submitted, the pre clearance rules will process and the decision on the request will be displayed soon after. And as you can see here, in this particular case, the request has been denied and this will this will be because the security was actually part of a restricted list. So, hopefully, that gives, a quick look and feel of the Comply platform and some of the key functionalities firms can use to operationalize, their employee monitoring processes.