The adherence to a voluntary code will only come about if firms judge it to be in their interest and take the practical steps to ensure the code is embedded in their practices. Firms will need to take practical steps such as training their staff and putting in appropriate policies and procedures.
We will probably recommend widespread use of attestations by firms about their adherence to demonstrate how widely the Code is followed. Firms are more likely to adhere to the Code if they believe that their peers are doing so too.