Article 8 Conflicts of interest
1. The code of conduct shall require a contributor to establish systems and controls concerning the management of conflicts of interest that include at least the following elements:
(a) establishment of a conflicts of interest policy that addresses:
(i) the process for identifying and managing conflicts of interest, including any internal escalation of conflicts of interest;
(ii) steps to prevent, or minimise the risk of, conflicts of interest in the process for recruiting submitters;
(iii) steps to prevent, or minimise the risk of, conflicts of interest in the remuneration policies for the contributor's staff;
(iv) steps to prevent, or minimise the risk of, conflicts of interest arising from the contributor's management structure;
(v) requirements with respect to communications between submitters and other staff within the contributor's organisation;
(vi) any physical or organisational separation between submitters and other staff of the contributor required to prevent, or minimise the risk of, conflicts of interest;
(vii) rules and measures to address any financial exposure that the contributor may have to a financial instrument or financial contract which references the benchmark to which the contributor contributes input data;