Overview
This policy is part of Our Code, which all colleagues are required to attest to on joining the Bank and annually thereafter.
Why do we need this policy?
The principles of integrity and impartiality are crucial in maintaining public confidence in the Bank. Our personal financial transactions should never influence, or be influenced by, our work at the Bank.
We regulate a number of listed companies and because of the unique role of the central bank, many of us are involved in making or advising on policy decisions that could influence the value of certain assets – for example, securities issued by financial institutions, or foreign exchange.
It is essential that proper arrangements are in place to allow both the Bank and you to show that individual investment and borrowing decisions have not been influenced by market sensitive information made available to you confidentially while working at the Bank, and to show that work decisions could not be, or were not, influenced by personal factors. Civil and criminal sanctions apply to market abuse and insider dealing summarised in the guidance on the UK Market Abuse Regime, and we all sign a Declaration of Secrecy when joining the Bank.
This policy and the requirements it contains, sets out how these risks are managed for the Bank and for us all.
Who does this policy apply to?
This policy applies to all colleagues employed by the Bank. This includes consultants, contractors and agency colleagues.
What you must know or do
This policy covers the requirements for financial transactions you would like to carry out. There are some transactions – set out in Section 2 – that are not permitted. There are other transactions that require advance approval – these are set out in Section 3.
Please see the Financial Relationships policy for declarations you may need to make about your continuing relationships with financial firms.
1: General principles
1.1. You must not under any circumstances seek to make a profit or avoid a loss by making use of information acquired while working at the Bank.
1.2. You should exercise caution in the management of your finances.
1.3. Dealing in securities on the basis of inside – ie unpublished, price sensitive – information is a criminal offence. All employees are expected to be familiar with the contents of the guidance on market abuse and the related prohibitions on insider dealing.
1.4. You are reminded that even though you may wish to carry out a transaction very quickly, you must not do so before you have received the necessary approval.
1.5. You can use ConflictsChecker to help you work out whether you need to seek advance approval for the saving, investment, divestment or borrowing that you want to carry out.
2: Transactions that are not permitted
2.1. You must not carry out transactions that might embarrass the Bank or harm its reputation.
2.2. You must not carry out transactions whose main purpose is speculative (eg to make a profit or avoid a loss in the short term) including transactions in cryptocurrencies.
2.3 Colleagues who have, or may be reasonably perceived to have, inside information regarding cryptoassets while working at the Bank are not permitted to acquire cryptoassets (and must obtain approval in advance via the transaction request form in the Our Code Compliance system should they wish to divest of any existing holding). You must declare your holdings under the financial relationships section of the Our Code Compliance system (see the Financial Relationships policy)
2.4. You must not bet on financial variables or indices or cryptoassets. You are not permitted to take out a contract for differences (see definition in Section 9), which includes ‘spread betting’, in relation to securities, UK indices/sectors or economic variables of direct interest to the Bank and its forecasting processes (eg commodity, currency markets) or the UK equity market as a whole.
2.5. You are not permitted to acquire financial instruments (such as debt, equity, or derivatives) in any entity regulated by the Bank, including PRA-regulated firms and Critical Third Parties, or their financial holding companies.
2.6. To find out whether a firm is Bank-regulated search for and select the firm via the Financial Services Register, then expand the ‘Regulators’ section. For a list of Financial Market Infrastructure (FMI) firms we supervise (also included in the Bank-regulated definition) see the FMIs we supervise section on the Bank’s website.
2.7. If you joined the Bank with holdings in an entity regulated by the Bank you may retain them but you must declare your holdings under the financial relationships section of the Our Code Compliance system (see the Financial Relationships policy). You must not acquire more or actively manage them. If you exercise your rights in relation to your prior holding or sell these securities, you must obtain approval in advance via the personal financial transaction request form in the Our Code Compliance system.
2.8. You are not permitted to invest in collective investment schemes that are unduly weighted towards investments in the financial services industry. A balanced portfolio may contain some financial securities but individual funds that are more than 45% invested in financial services securities are unlikely to be approved.
2.9. In exceptional circumstances, additional restrictions on transactions may be imposed on relevant colleagues during periods of significant stress in financial markets. This would be agreed by the Governor and the Secretary and communicated to the individuals concerned.
3: Transactions that require advance approval
3.1. The transactions for which advance approval must be sought include:
I. Dealings in exchange-listed securities and related investments (including gilts), and commodities such as precious metals (eg gold).
II. Dealings in collective investment schemes (eg unit/investment trusts and stocks and shares ISAs) where the value of the investment is more than £5,000 per transaction. Investments in collective investment schemes valued at £5,000 or less do not require advance approval.
Transactions through crowdfunding and peer-to-peer lending platforms require advance approval where they are substantially the same as an investment, rather than a donation. You do not need to seek approval for dealings in investments in the core funds permitted within the Bank’s Supplementary Pension Plan or for investments in cash ISAs.
III. Transferring more than £5,000 from a bank or building society regulated by the Bank where you have a cash balance greater than the Financial Services Compensation Scheme (FSCS) limit (currently £120,000 per person per firm) to an account at another institution (including National Savings and Investments).
You should not split up financial transactions in order to circumvent requirements II or III. You do not need to seek approval for transfers made within the same institution, or for payments made to others for goods and services (eg paying a solicitor for services when purchasing/selling a house).
IV. Setting up or transferring a personal pension plan, and taking or approving decisions relating to the investments within such a plan.
Switching between funds within the Bank’s Supplementary Pension Plan does not require approval.
V. For colleagues included in the below groups, arranging a mortgage on a property, whether for your own use or for investment purposes. Requirement covers:
- colleagues on the Monetary Policy Committee (MPC) insider list (including all MPC members and supporting offices);
- colleagues working in the Monetary Analysis (including those in the external MPC Unit), Markets and International directorates;
- the Executive Director, Communications (and their office);
- the Head of Division, Stakeholder & Media Engagement; and
- members of Court or the statutory policy committees (including private offices).
‘Arranging’ in this context means entering into a new or revised agreement to borrow on stated terms and conditions. Approval must be sought once a mortgage offer is received and before it is accepted.
VI. Transactions in foreign exchange that seek to hedge or take a position.
You do not need approval for transactions in foreign exchange relating to the purchase of goods or services, or to an investment that has been separately approved under this policy. Where you have not previously sought approval, but you wish to reverse a transaction in foreign exchange made within six months because of market movements, you do need to seek approval.
VII. Any financial transaction not specified above but which, in the nature and spirit of these rules, could reasonably be seen as sensitive.
This would include, for example, withdrawing deposits from a firm where you know of contingency planning being carried out for that firm, or are aware of adverse stress testing results or a breach of regulatory requirements by the firm, or are aware that the firm is planning to access the Contingent Non-Bank Financial Institution Repo Facility, or where you are involved in any intervention by the Bank with respect to that firm. During ‘quiet periods’ (defined in the publicly available MPC and Financial Policy Committee (FPC) Communications Codes) certain transactions by those on insider lists for MPC and FPC meetings will not ordinarily be permitted.
4: Exemptions where investments are under full discretionary management
4.1. Exemptions from the full requirements of the policy are available where your investment assets are managed by a portfolio manager, both personal and via a robo-advisor platform, who has full discretion over investment decisions on terms that have been specifically approved in advance by the Secretary or the Conflicts team in the Secretary’s Department via AskConflictsAdvice.
4.2. We require you to sign up to a set of undertakings to provide assurance that day-to-day control over all investment decisions – which include security selection and asset allocation – would rest solely with the portfolio manager once the mandate has been agreed, and that you will not provide any instruction relating to, or otherwise directly or indirectly influence, such decisions.
4.3. Where you are selecting specific investments or collective investment funds yourself, even where these are index-tracking funds, this would not be considered full discretionary management, and you must refer to Section 3 of the policy to assess whether advance approval is required.
4.4. Where a discretionary management arrangement has been approved by the Conflicts team, the restrictions (Section 2) and requirement for pre-approvals (Section 3) in the policy no longer apply.
5: Carrying out transactions for, or by, others
5.1. These rules cover transactions you carry out on your own account, and where you are directing and advising on the investment decisions of another individual (eg a spouse, partner or child) or organisation, including where you are acting as executor of a will, trustee, director, or shareholder. Transactions undertaken independently by others on their own initiative generally do not need approval (see Section 10 for the additional requirements that apply in relation to members of Court and the statutory policy committees).
5.2: You must not give advice to another person on transactions in regulated institutions and must not divulge, take advantage, or encourage others to take advantage of information that may be considered as inside information. You should refer to your Local Reporting Officer in any case of doubt about giving advice to another person.
6: Trustees of charitable organisations
6.1. If you are invited to become a trustee of a charitable organisation, you must advise your Line Manager, explain what the role as trustee involves and agree on the degree of involvement in and reporting of investment decisions in specified circumstances (which will depend upon the particular information which may become available to you as a result of your Bank work). You need to disclose an appointment as a trustee via the Our Code Compliance system. See the Community and Charity Roles policy for more information.
6.2. In the case of a charity, if you were to sit on a trust’s investment committee you would be assumed to be acting in an advisory capacity or have an oversight role. If you also had responsibility for approving investments or financial transactions, then this would require reporting of the trust’s relevant financial relationships and seeking advance approval for relevant personal financial transactions under those policies. Merely being a member of the general body of trustees (absent indications to the contrary) would not require transaction reporting. Trustees must be particularly careful not to offer investment advice at Trust meetings and to make it clear (and have it minuted by the Trust) that they cannot.
7: How will my request for approval be treated?
7.1. Personal financial transaction requests are screened centrally for errors or omissions and for Bank-wide sensitivity by the Conflicts Team in Secretary’s Department before being forwarded to your Local Reporting Officer. Reporting Officers will usually be in your management line, as they are most likely to know what specific information you may have access to in your work.
7.2. Local Reporting Officers will not approve transactions where you have – or might be reasonably perceived to have – relevant information that is not in the public domain, for example, about decisions, publications or announcements made by any of the Bank’s senior policy committees (including the FPC, MPC, Prudential Regulation Committee (PRC) and Financial Markets Infrastructure Committee (FMIC)). Local Reporting Officers will also consider whether the proposed transaction gives rise to any sensitivity about work you are currently involved in.
7.3. Generally, your Local Reporting Officer will not approve dealings that appear to be short term and speculative and will question and may not approve the reversal of a transaction within six months – depending on the circumstances this may be treated as a breach of Our Code. This is for the protection of both you and the Bank, as such transactions could result in a perception of an abuse of information much more easily than for other transactions.
7.4. If a transaction is carried out before approval is received, this will be treated as a breach of the policy.
8: Can I appeal a decision?
8.1. Appeals may be made to the Secretary or Deputy Secretary in relation to local rulings on specific transactions. The Bank will review all cases carefully but must, necessarily, retain the final decision to approve or decline a transaction based on its assessment of all of the factors.
8.2. The Bank will not be liable for any claims for losses sustained, or profit not achieved, as a consequence of constraints it places on an individual’s ability to undertake personal financial transactions.
9: Monitoring and approval process
9.1. Internal Audit, Compliance Division and Secretary’s Department have a remit to consider the adequacy of the Bank’s safeguards in respect of personal financial transactions. Under certain circumstances, for example, in connection with one of the Bank’s formal processes, it may also be necessary for information to be made available to People Directorate, Legal Directorate and relevant senior management.
9.2. From time to time, further information may be requested from individuals (by the Secretary’s Department or by the Compliance Division) in relation to their reportable financial decisions, for example relevant bank statements or appropriate tax returns.
9.3. Local Reporting Officers who have any suspicions or doubts about transactions being carried out by a colleague should raise this with the Secretary or the Deputy Secretary or with the Compliance Division.
Definitions
For the purposes of the financial reporting sections of this policy, the words and expressions set out below have the following meanings:
Bank-regulated firm: Firms regulated by the PRA, Financial Market Infrastructure firms (see link to FMI supervision webpage on the Bank’s website) or Critical Third Parties that are regulated by the Bank.
Collective investment schemes: Sometimes known as a ‘pooled investment’. A fund that a number of people contribute to. A fund manager invests the pooled money in one or more types of asset. This includes unit and investment trusts, OEICs (Open Ended Investment Companies) and exchange traded funds, including any held in a SIPP, ISA or other wrapper.
Contract for differences: A contract between an investor and an investment bank or other counterparty. At the end of the contract, the parties exchange the difference between the opening and closing price of a specified financial instrument, including shares or commodities.
Cryptoasset (see link to cryptoasset explainer on the Bank’s website): A cryptographically secured digital representation of value or contractual rights that uses a form of distributed ledger technology and can be transferred, stored, or traded electronically (examples include Bitcoin and Ether) that is not a tokenised bank account, tokenised deposit or any other UK regulated instrument.
Dealings: Include purchases, sales, subscriptions, transfers or other dealings in, securities and related investments. This includes taking up rights issues (including any decision to elect for scrip dividendsfootnote [1]) or acquiring any rights or interests in securities and related investments.
Investment portfolio: Investments in securities and related investments or collective investment schemes.
Local Reporting Officer: Usually an individual’s Head of Division (Director or above if the individual is a Head of Division), or another Head of Division in the same Directorate, who is responsible for screening and approving or rejecting transaction requests from a local area perspective once a transaction request has been centrally screened by the Secretary’s Department.
Securities and related investments: Include shares (as well as individual company shares held in ISAs or other wrappers), bonds, debentures, other forms of securitised debt, commodities (such as precious metals) and any other financial investments, including debt instruments, futures, forwards, options, swaps, and other financial derivatives.
10: Additional requirements for all members of Court and the statutory policy committees
10.1. In addition to the requirements set out above, Court members, and members of the statutory policy committees (the FPC, MPC, PRC and FMIC), along with Executive Directors who are members of a statutory policy committee, must report their stock of financial assets and liabilities annually. This group reports via a Declaration of Interests form to the Secretary, and sign that their Declaration is accurate.
10.2. It is highly undesirable for members of this group to be actively involved in managing an investment portfolio, even within the transaction approval arrangements. Accordingly, those who hold a material investment portfolio are strongly advised to place it under full discretionary management on terms approved in advance by the Secretary.
10.3. Members of this group are expected to make themselves aware of any transaction of the nature covered by these rules by close family members (ie spouse, partner, minor children or other close family who live within the same household) that could embarrass the Bank or harm its reputation.
10.4. Members of this group are expected to keep records of their personal financial transactions and of the aforementioned close family members, for at least five years, and on request make them available to the Bank.
10.5. The reporting lines for this group in relation to any disclosures and proposed transactions are as follows:
10.5.1. The Governor refers, via the Secretary, to the Chair of Court.
10.5.2. Other members of Court and the statutory policy committees refer to the Secretary. The Secretary may consult the Governor or Chair of Court in the event the application of this policy to a proposed transaction is unclear.
11: Protecting your information
11.1. The application of this policy will be in accordance with the relevant data protection legislation. For information on how the Bank processes your data, please see our staff data privacy notice.
For all colleagues
1. You must obtain advance approval for the transactions listed in Section 3 of this policy.
1.1. You must give sufficient notice via the personal financial transaction request form in the Our Code Compliance system (usually at least five working days’ notice).
2. You must wait until advance approval has been granted before carrying out the transaction. You must not carry out the transaction if approval has been refused.
3. Once approved, you should execute a transaction promptly (within two weeks for investments and within six weeks for agreeing to mortgage terms), having regard to the nature of the transaction itself.
3.1. If, once your transaction request has been approved, you execute or complete it on a different timescale or basis from that indicated in your original notification, you must provide an explanation to the Local Reporting Officer via the Our Code Compliance system, and you may have to re-apply for approval. Unless otherwise specified by your Local Reporting Officer, once you have received approval you may execute the transaction, even if earlier than proposed in your request.
For all Local Reporting Officers (Heads of Division and above)
4. You must promptly review any Personal Financial Transaction requests via the Our Code Compliance system.
5. Contact the Conflicts Team if you have any questions about a Personal Financial Transaction request you have received.
What support is available to help you comply with this policy?
The following link will aid your understanding of, and compliance with, this policy:
Please see the Financial Relationships policy for declarations you may need to make about your continuing relationships with financial firms.
What is the impact of non-compliance?
If you realise you have breached – or suspect that you might have breached – a requirement in this policy please tell AskCompliance as quickly as possible, so that the issue can be reported and redressed under the Bank’s Breach Management policy. The Bank gives credit for you taking prompt responsibility for your mistakes. You should be aware that failing to discharge your responsibilities could lead to disciplinary or other action taken under the Bank’s other formal processes.
January 2026