Select Vantage Canada Inc. (“SVC”) will develop, implement and maintain written policies and procedures applicable to all Approved Persons, employees and all individuals who enter orders on behalf of SVC, and its parent Select Vantage Inc. (“SVI”), regardless of their location, to ensure appropriate monitoring of all trading-related activity.
SVC will develop and maintain a supervision system appropriate for its business, reasonably designed to prevent and detect orders or trades that may interfere with market integrity or fair and orderly markets. At a minimum, its supervision system will be designed to prevent and detect any activity prohibited by the Universal Market Integrity Rules, including but not limited to the provisions regarding manipulative and deceptive activities. The supervision system should also be reasonably designed to ensure the proper use of unique identifiers as required under Item 4.
SVC will report in the form and manner acceptable to CIRO each instance where SVC detects orders or trades that it reasonably believes to be within the meaning of manipulative or deceptive trading practices as set out in UMIR 2.2 and Policy 2.2.
SVC will include a unique identifier on each order message generated. The unique identifier must identify the individual who originated the order. This identifier will be available to CIRO in the form and manner acceptable to CIRO.
SVC will provide initial and on-going training as appropriate to all individuals who enter orders, or supervise such individuals, on behalf of SVC, and its parent SVI, regardless of their location. No individual will be permitted to enter any orders intended for entry on a marketplace where CIRO is the regulation services provider until initial training is completed and SVC is satisfied that the individual demonstrates satisfactory competency. SVC must maintain a record of its training for each individual.
Individuals entering orders on behalf of SVC and SVI will only be permitted to trade out of the SVC designated locations and through the SVC systems. SVC will not permit individuals trading on its behalf or the supervisor/managers of those locations to work remotely.
SVC will ensure that traders trading on behalf of SVC and SVI are not trading on behalf of any other person.
SVC will have at a minimum one Trader (registered as a Dealing Representative) who is an Executive responsible for operations at SVC who must also be designated and approved as a Supervisor. SVC will also designate a back-up Trader and Supervisor. The additional Supervisor must be the Chief Compliance Officer.
The Ontario Head Office location will be registered as a Business Location and will be the location of SVC’s Executives, Supervisor, Trader and any other Approved Persons.
In addition to any other notices required to be provided to CIRO, SVC must notify CIRO staff and obtain their non-objection before making any material changes to the following:
trading related policies and procedures, or structure
changes to the (geographical) locations where individuals conduct trading on behalf of SVC
its surveillance systems
its supervisory system
its training program and ensure in advance that it is acceptable to CIRO staff