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OMFIF Rules

What are the OMFIF Rules?

The OMFIF Rules are a high-level code of conduct to guide participants in OMFIF meetings. They are designed to prevent issues that could harm OMFIF and its members, such as revelatory leaks to the media (either direct or indirect, via connected persons who may not necessarily work for media companies) or disclosure of information that could result in legal restrictions on trading in shares or other investments.  

OMFIF Rules:

All participants in OMFIF meetings are expected to observe OMFIF’s commitment to the highest professional and ethical standards. By attending an OMFIF meeting (whether as a speaker, moderator or other participant), you are deemed to agree to observe the following rules during and after the meeting:

1. OMFIF meetings are ‘off the record’, unless you are notified to the contrary. This means that unless OMFIF has notified you that an OMFIF meeting is on the record or a speaker has specifically stated that his or her comments are free for outside distribution:

  • You must not disclose the contents of an OMFIF meeting to any party outside your organisation (including, in particular, the media); and
  • You must not say or do anything that could enable views expressed during an OMFIF meeting to be attributed to an individual or organisation.

2. You must observe applicable market conduct rules and must not disclose any material non-public information (or ‘inside information’) that could impact the price of shares or other investments.

3. You must not disclose any information on any matter that could cause you to breach a duty of confidentiality (for example, to your employer or to the organisation or institution you represent).

What is your role in upholding the OMFIF Rules?

  • To inform participants that the OMFIF Rules are in force.
  • To ensure that participants understand that the meeting is off the record.
  • To intervene if you suspect that a participant may be about to disclose information that they are legally not permitted to disclose or that is otherwise inappropriate for an OMFIF meeting. 

What does ‘off the record’ mean?

This phrase can mean different things, but for OMFIF, it means that participants must not:

  • Discuss statements made at OMFIF meetings with parties outside their organisation (especially media).
  • Do anything to enable statements made at OMFIF meetings to be attributed to a speaker or organisation.   

What are the exceptions?

In general, all remarks made at OMFIF meetings are off the record. [1] However, there are some important exceptions, which, in cases where they apply, need to be clearly stated and understood:

  • Where a speaker’s opening remarks, as part the stated communication policies of the institution that he or she represents, are deemed as on the record. This could, for example, be because the remarks are part of an agreed policy under which they are placed immediately on the institution’s website. In such cases, the speaker’s further interventions, in explaining and elucidating the earlier remarks, are normally deemed as off the record, in line with general OMFIF procedures.
  • Where a speaker, with the appropriate authorisation from his or her institution, has stated, ether spontaneously or as part of a previously elucidated policy, that either the whole, or certain parts, of a statement that he or she makes should be deemed as on the record.

What type of information should not be discussed during OMFIF meetings?

OMFIF encourages candid discussion, but participants must not disclose information they are legally not permitted to disclose or that is otherwise inappropriate for discussion during an OMFIF meeting.  

In particular, participants must not disclose ‘inside information’ (non-public information that could influence the price of shares or other investments) or information they are contractually / professionally bound to keep confidential. 

Examples of information that generally should not be discussed during OMFIF meetings:

  • Information that could impact the price of shares in public companies (e.g. details of significant transactions, anti-trust investigations, introduction of new taxes or regulation).
  • Imminent policy announcements (e.g. changes to interest rates or taxes; monetary stimulus).
  • Inside ‘tips’ or revelations relating to governments, large institutions or public companies; statements designed to encourage participants to buy or sell shares or investments.

What should you do if you suspect someone is about to disclose inappropriate information?

If you suspect that someone is about to disclose inside information, confidential information or other inappropriate matters, it is important that you intervene and steer the discussion to alternative ground.

However, participants should reach their own conclusions about whether inside information has been disclosed and any resulting trading restrictions – it is important that you do not pre-empt this in any way (e.g. by advising that inside information has, or has not, been disclosed).    

If you have any concerns about any matters discussed during the meeting, please inform an OMFIF representative, who will ensure that appropriate steps are taken.

 


 

1 This does not apply to a certain category of OMFIF meetings, the OMFIF City Lectures. The OMFIF City Lectures are open to a wider audience (including the media) and the relevant lecturer’s remarks are specifically designed to be public statements. When the lecturer is answering questions, he or she may, however, deem that the answers are off the record. In such event they should inform the audience that their remarks are off the record.