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15.4.1

A Trading Member's research activities must be separate from its dealing, corporate finance and back office operations. Separation means at least having the following:—

(1) separate reporting lines in place between the research activities and the other activities;
(2) adequate restriction of communication and information flow between the research activities and the other activities to avoid influencing research activities;
(3) adequate procedures to avoid any conflict of interest that may arise from the research activities and the other activities; and
(4) bonus, salary or other form of compensation to a research analyst not being based on any corporate finance or dealing transaction.