Adam Frankel
General Counsel · Technology & AI
15+ years as General Counsel to technology, cloud & AI companies
Market Conduct Policy (UK) by Study Academy
Study AcademyUpdated 28 Nov 2025
Market Conduct Policy sets mandatory standards to prevent market abuse, manipulation and improper use or disclosure of non-public information. Developed by the Study Academy Compliance team, specialists in accredited UK compliance training.
Market Conduct Policy (UK, 2025 Edition)
Purpose
To ensure that all dealings in financial, commodity or information markets undertaken by or on behalf of the organisation are conducted with integrity and in accordance with UK law, thereby preventing market abuse, unfair dealing or misuse of confidential information.
Scope
Applies to all staff engaged in trading, research, investment, financial analysis, advisory or any activity that could influence a market or rely on confidential/inside information.
Policy Statement
The organisation prohibits market manipulation, unlawful disclosure of inside information, front running, collusion on pricing, or any behaviour that could amount to market abuse.
Legislative and Regulatory Framework
UK Market Abuse Regulation (UK MAR) (retained EU law)
Criminal Justice Act 1993 (insider dealing)
Financial Services and Markets Act 2000 (as amended)
Companies Act 2006 (directors’ duties re: inside information)
Competition Act 1998 (anti-collusion)
Controls
Information barriers and need-to-know access controls.
Pre-clearance of personal account dealing (where relevant).
Insider lists and event-driven restricted lists.
Immediate reporting of suspicious transactions or orders.
Training and Awareness
Staff shall be trained to recognise inside information, handle confidential information appropriately and avoid improper disclosure.
England & Wales note
This version is drafted for England & Wales. Scotland and Northern Ireland differ on some points — for example notice periods and tribunal procedure. Tell GitLaw where you hire and it adjusts the draft.
Jurisdiction
England & Wales
Document info
HTML document. Document created on Fri Nov 28th, 2025. Last updated on Fri Nov 28th, 2025.
This document is public
Licensed under CC0 1.0 Universal.
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