One positive indicator would be if firms identify and rectify individual misconduct cases quickly. Another would the absence of widespread conduct issues across firms. But we will want also to understand how the Code is affecting market functioning in a deeper sense. To this end, the GFXC plans to survey regularly market participants. This will enable us to track some of the less tangible indications of success, such how the Code is impacting and improving behaviours – transparency around pre-hedging for example – and how the Code is being embedded in the market through firms’ adherence expectations of their counterparties. An initial survey will be launched later this month, to give a benchmark against which subsequent survey results can be compared. I have no doubt of the commitment of many in the market to ensure success. What is needed now is to embed that attitude across the market as a whole and to ensure that our efforts so far translate into real improvements. Improved culture and attitudes regarding market conduct;  Improved confidence for end users that they are transacting at competitive prices;  And ultimately, a market that more effectively serves its economic purpose. So in closing I would ask again for your help in achieving that change. The success of the Code will depend above all else on the continued efforts of all involved in the market. Central bankers will remain deeply engaged, but to secure success we will be relying on the partnership with market participants that we have fostered.
Seeking broad adoption  So if we have reached the point where a new Code has been launched and there are encouraging early moves on adoption, what needs to follow? Most obviously, it’s important that we maintain this early momentum so that adoption becomes the norm. As I have already implied, virtually all of the firms directly engaged in developing the Code have publically stated their intention to sign up, and members of the various central-bank organised foreign exchange  4  http://www.globalfxc.org/public_registers.htm?m=62%7C379 3  All speeches are available online at www.bankofengland.co.uk/speeches  3  committees across the globe will do so too. This captures many of the large sell side firms and infrastructure providers. The challenge at this stage is to ensure that firms engaging in the full range of wholesale market activities are equally committed to incorporating the Code into their business practices. The audience in this room represents a key constituency: buy-side participants. A traditional, though I hope fading, attitude is to view codes of conduct as the preserve of sell-side firms only. But the Code provides key guidance that is relevant to both sides of any FX transaction. Moreover, an objective behind providing principled rather than rules-based guidance was to encourage market participants to think through how those principles apply to their own business context, and to apply the Code in a manner which is proportionate to that context.