(1) A proxy advisor ("P") must take all appropriate steps to ensure -

(a) that P identifies any actual or potential conflict of interest or any business relationship that may influence P in the preparation of research, advice or voting recommendations; and

(b) that such a conflict of interest or business relationship is identified without delay after the time at which it arises.

(2) Where P has identified an actual or potential conflict of interest or a business relationship of the kind specified in paragraph (1), P must, without delay -

(a) disclose that fact to P's clients together with particulars of the conflict of interest or business relationship concerned; and

(b) give P's clients a statement of the action P has undertaken to eliminate, mitigate or manage the conflict of interest or business relationship concerned.