THE CHALLENGE
A critical compliance program had become difficult to maintain accurately and efficiently.
The Code of Ethics program required significant remediation to support accurate regulatory reporting and recordkeeping. The compliance management system was disorganized, employee disclosures required extensive review, and manual processes around brokerage statements and personal trading verification created additional operational complexity.
THE investigation
Understanding the system before redesigning it.
The work began with a comprehensive assessment of how the Code of Ethics program operated across policy, technology, data and day-to-day compliance workflows.
01
Policy & Regulation
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Policies & procedures
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Regulatory reporting requirements
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Historical records
the goal
Identify where policy requirements, system configuration and day-to-day employee activity were falling out of alignment.
02
Systems & Data
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Compliance system configuration
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Account & transaction data feeds
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Brokerage statements
03
Employee Activity
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Employee disclosures
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Personal trading workflows
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Manual review processes
THE STRATEGY
Move from fragmented remediation to a structured, sustainable compliance program.
A comprehensive Cleanup Project Plan was developed to systematically address account verification, brokerage statements, private investments, personal trading waivers and compliance-system configuration.
01 | REMEDIATE
02 | STRENGTHEN
03 | OPTIMIZE
Validate accounts, disclosures, statements and historical records.
Review personal trading rules, private investments and waiver processes.
Improve system organization, account data feeds and regulatory recordkeeping.
EXECUTION
Turning the strategy into action.
01
Conducted direct employee outreach to verify active brokerage accounts, statements, transactions and holdings.
02
Performed a comprehensive review of private investment disclosures.
03
Reviewed and validated personal trading waivers.
04
Evaluated the compliance management system and organization of personal trading rules.
05
Improved the accuracy and reliability of account data feeds and compliance records.
The Impact
A stronger foundation for an accurate, scalable and audit-ready Code of Ethics program.
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Improved organization of personal trading rules
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More accurate account data feeds
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More reliable employee disclosures
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Stronger regulatory record-keeping
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Reduced dependence on fragmented manual review
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Greater confidence in the integrity of Code of Ethics data
200+
Employees supported
LEADERSHIP TAKEAWAY
“Strong compliance programs are not built around individual checks. They are built around systems that make accurate oversight repeatable.”
This work required looking beyond individual compliance issues to understand how policy, technology, data and employee behavior interacted across the broader Code of Ethics program.
Sands Capital Management