How We Do It: Conduct & Ethics

The Conduct & Ethics Committee, jointly chaired by Gareth Murphy and Alison Higgins, examines conduct matters covering behaviour, controls, oversight functions and methodologies across wholesale markets. The Committee has recently published a Transparency Draft on unauthorised trading and also re-examined front-office supervision in the light of developments in how supervision is conducted. Other areas of recent focus include how firms collect and use conduct and culture management information, and how the 3 Lines Model of defence can be applied more widely in risk management.

“FMSB is a highly effective forum for bringing together senior practitioners from across wholesale markets to develop industry standards and guidance. Cross-industry collaboration on conduct and ethics continues to be of vital importance as markets evolve and is often a better approach than additional regulation.”

Gareth Murphy, FMSB Advisory Council Member, Co-Chair of the FMSB Conduct & Ethics Committee and Group Chief Risk Officer at Aberdeen Group plc

“I am delighted to be co-chairing FMSB’s Conduct & Ethics Committee with Gareth. The issue of unauthorised trading is particularly pertinent amid rapid developments in technology and our working group on this topic is already developing good practice guidance to support firms in managing these risks.”

Alison Higgins, Co-Chair of the FMSB Conduct & Ethics Committee and Global Head of Control, Financial Markets Head, Markets (UK, Europe and America) at Standard Chartered

Work in Progress

Unauthorised trading

Trading controls comprise a subset of front, middle and back-office controls that are necessary to prevent or detect incidents of inappropriate or unauthorised trading. A Working Group is focusing on driving a consistent understanding of key terms and clarifying expectations of good practice, and a Transparency Draft on the topic was published for public consultation in July 2025.

Topics under consideration

Non-financial misconduct

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