3904. Policies and procedures

A Dealer Member’s policies and procedures must establish  a supervisory system to supervise the activities of all its employees and Approved Persons that provides reasonable assurance they comply with IIROC requirements and securities laws.

As part of its supervisory system, the Dealer Member, at a minimum, must:

1. have policies and procedures that specifically address supervision of its employees and Approved Persons, 

2. have policies and procedures relating to supervision that provide reasonable assurance of compliance with IIROC requirements, securities laws and applicable laws, 

3. ensure all supervisory policies and procedures are in writing, and

4. amend its  policies and procedures relating to supervision within a reasonable time after changes in IIROC requirements, or securities laws are made.  

A Dealer Member must communicate its policies and procedures to all relevant employees and Approved Persons and must:

1. provide its sales and supervisory employees and Approved Persons with the Dealer Member’s sales practices policies and procedures relevant to their functions,

2. obtain and record acknowledgements from all sales and supervisory employees and Approved Persons that they have read and understood the policies and procedures relevant to their respective roles and responsibilities,

3. provide introductory and continuing education to all Approved Persons on the Dealer Member’s policies and procedures and any relevant changes to them, 

4. communicate information relating to IIROC requirements and applicable laws, to all sales employees and other Approved Persons to whom it is relevant,

5. have policies and procedures that specifically address the method and timing of the distribution of compliance related notices,

6. promptly communicate changes in its policies and procedures to all relevant employees and Approved Persons, and

7. have procedures to provide reasonable assurance that each employee and Approved Person understands their responsibilities under the Dealer Member’s policies and procedures.