1.  Depending on the size and complexity of the organization, the Manager should endeavour to cross-train personnel or otherwise have appropriate back-up, so that key operations functions are not dependent solely on one individual.
[See also Section B2 (11)]

1.  No applicable guidance.

2.  The Manager should regularly assess the appropriate level of staffing and resources for complex or unique trading strategies from an operational and business risk perspective and be willing to maintain that level.
[See also Section B2 (11)]

2.  No applicable guidance.

3.  The Manager should establish a robust training program to educate personnel in respect of its compliance program.
[See also Section A3 (5)]

3.  This training program should be developed in light of the following considerations (to the extent relevant):

• training should foster an understanding of all parts of the compliance framework;
• training should be tailored to the type of business undertaken by the Manager and should incorporate examples relevant to that business. It should focus on identifying compliance issues particular to the manager’s operations and on preventing market abuse;
• at least annually the Manager should organize and make available to personnel performing a significant business function a compliance training session addressing topics identified by the Chief Compliance Officer and by employees as relevant to the activities of such employees. The Manager may enlist the services of outside experts, such as outside counsel, to conduct these sessions;
• training should address circumstances where it would be appropriate to seek guidance from the Chief Compliance Officer or other member of senior management regarding a compliance matter; and
• because junior personnel will often develop greater compliance awareness through open and informal discussions with their supervisors and the Chief Compliance Officer, such contact should be encouraged as part of the training process.