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In our response to this Consultation, we outline our thoughts on how existing industry practices could be improved to achieve the desired outcomes, while highlighting our concerns in relation to the publication of early details related to ongoing enforcement cases.

ODD plays a vital role in institutional investor processes. Our 2024 survey of ODD Practices reveals standard practices at leading investors across a range of areas including structures, use of data gathering tools, and challenges.

Discussions around trade errors, omissions, and breaches are sensitive given it is not a “zero failure” environment. In this memo, we explore the spectrum of approaches and treatment of these and highlight how investors and managers can improve dialogue for mutual success.