Examples of principles of particular relevance include:   Principle 8 (‘market participants should be clear about the capacities in which they act’, including to their own clients);    Principle 9 (‘market participants should handle orders fairly and with transparency in line with the capabilities in which they act’ – which assigns specific duties to clients, including being aware of  2  https://www.globalfxc.org/  3  eg https://www.newyorkfed.org/fxc/index.html, https://www.bankofengland.co.uk/markets/london‐foreign‐exchange‐joint‐standing‐committee or http://www.sfemc.org/ 4 https://www.theinvestmentassociation.org/assets/files/press/2018/FX%20Global%20Code_summary.pdf 5  https://www.theinvestmentassociation.org/assets/files/consultations/2018/20181105‐guidetosigninguptothefxgobalcode.pdf  6  https://www.treasurers.org/technical/codes 6  All speeches are available online at www.bankofengland.co.uk/publications/Pages/speeches/default.aspx  6  responsibilities they should expect of others, being aware of risks associated with the transactions they request and undertake, and regularly evaluating the execution they receive);   Principle 12 (‘market participants should not request transactions… with the intent of disrupting market functioning or hindering the price discovery process’); and    Principle 31 (‘market participants should have independent processes in place to mark-to-market trading positions to measure the size of their profit and loss and the market risk arising from trading positions’)  Throughout the whole Code, however, there is no suggestion of a ‘one size fits all’ approach: for buy-side firms, as for all organisations covered by the Code, proportionality is a key principle.
In my current role, as Executive Director for Markets at the Bank of England, Chair of the London Foreign Exchange Joint Standing Committee, and a member of the Global FX Committee, I have a responsibility to foster strong, efficient and fair foreign exchange markets in sterling and other currency pairs. But I was also in at the birth of the Code itself, because in 2014-15 I led the team that produced the Fair and Effective Markets Review, which recommended amongst other things that the ‘Global Preamble’ produced by national FX committees in March 2015 should be expanded into a full-blown Global Code, sweeping away the various national texts that preceded it, and setting a new standard for trading practices and behaviours in a market that urgently needed reform. Two years later, in May 2017, the Global Code was launched, setting out a common set of guidelines for good practice in the FX market. The Code contains 55 principles covering ethics, governance, execution 2  All speeches are available online at www.bankofengland.co.uk/publications/Pages/speeches/default.aspx  2  and transparency, information sharing, risk management, confirmation and settlement; and it tackles aspects of current and future market development, including electronic trading, algorithmic trading and prime brokerage. The drafting process was a truly global effort, taking two years and involving central banks and market participants, including buy-side, sell-side and end-users, from 16 jurisdictions around the world. Many of you, or your institutions, played a vital role in that process. Takeup of the Code, which is voluntary, has grown rapidly.