Effective Controls and Segregation of Duties
(a) A Trading Member must ensure effective controls and segregation of duties and separation between its research department and its corporate finance department and between each of them and its dealing and back office departments. Separation between departments means at least having the following:
(i) separate reporting lines in place for each of the different departments;
(ii) adequate restriction of communication and information flow, particularly non-public information, between the different departments;
(iii) adequate processes and procedures to identify, avoid, minimise, manage or mitigate any conflict of interest or potential conflict of interest between the different departments;
(iv) bonus, salary or other forms of compensation to a research staff member not being based on any corporate finance or dealing transaction; and
(v) access into the corporate finance department being restricted only to corporate finance staff members and any other authorised staff member.
(b) SGX-ST may require the Trading Member to implement controls and procedures to ensure proper segregation under Rule 4.39.4.