Well, more specifically – a “summary of the (non exhaustive) factors a firm might consider when developing a leak enquiry policy.”
It’s from the FSA and you can get a FREE copy of Market Watch 27 here.
How to decide when to begin an internal review
The policy should identify the factors that might trigger the firm to consider beginning an internal review, and who within the firm should have the responsibility to consider these. Factors could include:
• a specific request from the Takeover Panel, the FSA or a client;
• the specificity of media articles, including whether the information was something that would likely only be known by the firm;
• whether there was any strategic benefit or other rationale for the firm or specific individuals to leak the information;
• any information that indicates specific weaknesses, such as whistle-blowing reports, indications of a breach of Chinese Walls (including unusual trading by the firm’s proprietary desk);
• staff issues including whether any staff have recently joined or left the organisation, whether anyone might bear a grudge, whether staff are under undue pressure due to workloads, sickness or pressure on targets;
• suspicious PA dealing patterns;
• a spike in a share price shortly after the firm had been appointed;
• known relationships between insiders and the publisher of particular articles; and
• review of the deal chronology to determine any particular information gained in close proximity to the leak.
_____