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Relativity Trace Policies

Relativity Trace includes over 40 different policies in more than 5 different languages to identify risk within an organization. To ensure users get the most out of these policies, there is a formal Policy Enhancement Program (PEP) run by a Trace Subject Matter Experts to rightfully implement Trace and improve existing policies within an organization. To get access to these out-of-the-box policies and participate in the formal program please contact support@relativity.com.

  1. Policy List
    1. Corrupt Practices
    2. Inside Information
    3. Collusion
    4. Pharmaceuticals Sales Fraud
    5. Use of Personally Identifiable Information (PII)
    6. Market Manipulation
    7. Anti-Trust Violations
    8. Code of Conduct Breaches
    9. Gifts and Entertainment
    10. Customer Complaints - Financial
    11. Institutional Customer Complaints - Financial
    12. Social Trading Risks
  2. Language Support

Policy List

Corrupt Practices

Category Policy Description
Corrupt Practices Bribery Detect an employee offering, giving, receiving, or soliciting an item of value to influence an action of a key decision maker
Corrupt Practices Coercion and Intimidation Detect persuasion through force or threats.
Corrupt Practices Extortion Detect when someone is forced to feel indebted against their will and is offered “protection” in exchange for money or favors
Corrupt Practices Embezzlement Detect an attempt to engage in converting assets, entrusted to them via a financial institution or similar business function,for their own personal gain.
Corrupt Practices Guarantees and Assurances Detect a registered representative providing a guarantee against loss to a customer.
Corrupt Practices Foreign Corrupt Practices Detection (FCPA) Detect corruption and bribery with foreign officials and an attempt to keep from being discovered, in line with the United States Foreign Corrupt Practices Act (FCPA).
Corrupt Practices Money Laundering Detect the concealment of illegally obtained money by targeting specially designated nationals, block lists, and high-risk regions.
Corrupt Practices Political Solicitations Detect contributions to political causes that are offered or solicited, which may be against firm or regulatory rules and pose aconflict of interest.
Corrupt Practices Unfair and Unbalanced Trade Detect broker-dealers misleading customers or not complying with advertising rules of Financial Industry Regulatory Authority (FINRA) and the U.S. Securities and Exchange Commission (SEC).

Inside Information

Category Policy Description
Inside Information General Tipping Detect the sharing of potential material nonpublic information (MNPI) regarding general company information, financial information, or corporate actions.
Inside Information Rumors and Speculation Detect the distribution or discussion of unverified and doubtfully true information.

Collusion

Category Policy Description
Collusion Change of Venue Detect an attempt to avoid discovery by changing the communication venue (i.e., moving from email to phone call).
Collusion Collaborative Discussions Detect employees working together to prevent the discovery of misconduct.

Pharmaceuticals Sales Fraud

Category Policy Description
Pharmaceuticals Sales Fraud Kickbacks Detect pharmaceutical sales representatives paying “remuneration” to induce or reward patient referrals or the generation of business involving any item or service payable by federal health care programs.
Pharmaceuticals Sales Fraud Off-Label Selling Detect pharmaceutical sales representatives attempting to influence physician’s decisions to prescribe medications for a condition different from their intended or approved use.

Use of Personally Identifiable Information (PII)

Category Policy Description
Use of Personally Identifiable Information (PII) Credit Card Information Detect the sharing of credit card information.
Use of Personally Identifiable Information (PII) Social Security Number or Equivalent Identification Detect the sharing of United States passport, social security, drivers license and individual taxpayer identification numbers.

Market Manipulation

Category Policy Description
Market Manipulation Boasting (Market Content) Detect the excessively proud and self-satisfied talk by a trader of their achievements in regard to someone less fortunate.
Market Manipulation Front Running Detect traders attempting to buy or sell financial products ahead of other orders to lock in a better price.
Market Manipulation Layering Detect traders placing and then cancelling orders that they never intended to execute, with the intention of influencing the price.
Market Manipulation Mirror Trading Detect simultaneous buy and sell trades of the same stock on different exchanges by the same entity, as a way to move money between jurisdictions.
Market Manipulation Pre-Arranged Trading Detect traders agreeing on trade price in advance of execution.
Market Manipulation Price and Benchmark Fixing Detect agreements between traders to collectively manipulate the price of a financial product or a benchmark to adjust marketconditions.
Market Manipulation Pump and Dump Detect traders attempting to boost the price of a financial product after establishing a large long position by sharing falseormisleading information.
Market Manipulation Research Desk & unathorised Investment Advice Detects for misconduct where monitored individuals are providing unauthorized investment advice within firm publications.
Market Manipulation Short and Distort Detect traders attempting to decrease the price of a financial product after establishing a large short position by sharing false or misleading information.
Market Manipulation Forex Fix Rigging Detect agreements between traders to collectively manipulate benchmark foreign exchange rates (FIX) to artificial levels.

Anti-Trust Violations

Category Policy Description
Anti-Trust Violations Price-Gouging Detect raising the prices of goods to unreasonable levels to take advantage of demand or supply shock.

Code of Conduct Breaches

Category Policy Description
Code of Conduct Breaches Hate and Discrimination Detect inappropriate treatment of others based on race, color, religion, sex, national origin, age, disability or genetic information.
Code of Conduct Breaches Influencing a Regulator Detect someone attempting to have an effect on a regulator’s actions or decisions.
Code of Conduct Breaches Influencing Compliance Team Detect someone attempting to have an effect on a compliance team member’s actions or decisions.
Code of Conduct Breaches New Hires, Internal Transfers, and Terminations Detect monitored individuals who are breaching internal policies around the sharing of information.
Code of Conduct Breaches Sexually Explicit Language Detect sexually explicit language commonly used during sexual harassment.

Gifts and Entertainment

Category Policy Description
Gifts and Entertainment Excessive Entertainment Detect entertainment that breaches the gifts and entertainment company policy.
Gifts and Entertainment Excessive Gifts Detect gifts that breach the gifts and entertainment company policy.
Gifts and Entertainment Sporting and Events Detect expensed sporting events and other events that breach the gifts and entertainment company policy.

Customer Complaints - Financial

Category Policy Description
Customer Complaints - Financial Errors Detect customer complaints about errors causing customer dissatisfaction.
Customer Complaints - Financial General Detect customer complaints about a service or product sold via retail channels causing customer dissatisfaction.
Customer Complaints - Financial Suitability Detect customer complaints about recommendations that were made to them that they believe were knowingly unsuitable.
Customer Complaints - Financial Unauthorized Detect customer complaints about a group or individual who performed or completed a task or operation that was not authorized.

Institutional Customer Complaints - Financial

Category Policy Description
Institutional Customer Complaints - Financial Allocation Detect complaints from institutional clients regarding misallocation of funds.
Institutional Customer Complaints - Financial Dissatisfaction Detect general dissatisfaction complaints from institutional customers.
Institutional Customer Complaints - Financial Illegal Behavior Detect accusations of illegal behavior from institutional customers.

Social Trading Risks

Category Policy Description
Social Trading Risk Market Manipulation Tactics Detect a social platform user attempting market manipulation tactics of social platform users.
Social Trading Risk Social Trading Conduct Breaches Detect a social platform user breaching conduct set out by the social platform policy.
Social Trading Risk Social Trading Platform Risks Detect general social platform risks such as negative behavior towards services and complaints.

Language Support

Policies are supported in English, French, German, Italian, Japanese, Russian, Spanish. Support for new languages are being added in each release. Please contact support@relativity.com for language support requests.