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Personal transactions and inducements: financial services

Updating authors: Bridget Barker and Paul Ellison
Consultant editors: Nick Thorpe and Neil Johnston


  • Firms must maintain adequate arrangements to ensure that the personal transactions of their employees do not conflict with their duties to their customers. (See Personal transactions)
  • Although firms are not required to provide employees with a written policy on personal account dealing as part of their contract of employment, implementing and maintaining such a policy is still advisable. (See Personal transactions)
  • A firm must take reasonable steps to ensure that the firm, or any person acting on its behalf, does not offer, receive or solicit an inducement if this impairs compliance with the firm's duty to act in the best interests of the customer. (See Gifts and inducements)
  • Firms should have a policy on controlling gifts and inducements - both given and received - to avoid either the firm or its employees being unduly influenced in carrying out its duties to customers. (See Gifts and inducements)
  • If a firm acts as an investment manager executing customer orders in relation to shares, there are additional requirements. (See Use of dealing commission)