Appropriate 'Chinese Walls' have been established between Strate's two roles, namely, the role of performing security services as the appointed CSD and the role of a self-regulating entity tasked with supervision of compliance by CSD Participants. A 'Chinese Walls' manual details the structures that have been established and the procedures that must be followed to prevent the inadvertent spread of confidential information between these two roles.
The 'Chinese Walls' structures prevent STRATE Supervision from sharing confidential CSD Participant-related information with Strate's business units, but there are no confidentiality barriers in respect of Strate's business units sharing information with STRATE Supervision where a CSD Participant is believed to be contravening the FMA, CSD Rules and Directives or introducing risk into the market.
STRATE Supervision staff are bound by very stringent confidentiality and code of conduct clauses in their employment contracts. In addition, staff sign an annual declaration as confirmation of their understanding and adherence to the 'Chinese Walls' policies and procedures adopted by Strate.
All staff in the division are constantly reminded of their duty to observe the highest professional standards and are given clear guidance to avoid conflicts of interest, the possible abuse of confidential information, the observance of confidentiality and secrecy, and the observance of procedural fairness.
For more information, email: Strate-supervision [at] strate.co.za.