PERSONAL CONDUCT OF DEALERS WITH MONEY BROKERS

a)Dealers and brokers must not engage in unprofessional activities such as the use of orders (fictitious or otherwise) for the primary purpose of tracking potential counterparties so that they can deal with them directly.

b)No unprofessional conduct or means shall be used to persuade a counterparty to increase the order of an already done deal through a broker.

c)A dealer shall not, in any way, apply pressure to a broker by implying that his institution will increase or give additional business to the broker should the latter agree to what the dealer is asking for. Concrete examples of applying pressure to brokers are, but not limited to, the following:

c.1) A dealer requesting a broker to divulge information which will result in breach of the confidentiality agreement between the said broker with other dealers;

c.2) Soliciting excessive gifts and entertainment; Excessive gifts are defined in the Code of Ethics Governing Financial Markets Activities in the Philippines (BSP Cir Letter No. 2010-013)

c.3) A dealer asking a broker to perform personal favors which would be beneficial to the dealer directly or indirectly;

c.4) A dealer requesting for unusual entertainment from the broker. Unusual entertainment is defined in the Code of Ethics Governing Financial Market Activities in the Philippines (BSP Cir Letter No. 2010-013);

c.5) Other improper gestures or acts outside the strict scope of a broker’s professional responsibility.

d)Likewise, applying pressure by a dealer to a broker includes any statement which directly or indirectly implies, that failure of the broker to cooperate or give in to the request of the dealer would lead to reduced business of the dealer with the broker.

e)Any act committed by the dealer which is defined as prohibited in this section shall be reported in writing by the broker to the President and Head of Treasury of the FI where said dealer is connected. Likewise, any act committed by a broker who is defined as prohibited in this section shall be reported in writing by the dealer to the President or General Manager of the Money Broker Institution involved.