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Corporate Governance

Code of Conduct

The Australian custody industry has grown significantly over recent years due to the growth in superannuation and managed funds, and changes to the supporting regulatory frameworks. The importance of efficient, trusted and professional asset safekeeping and administration is now well recognised. 

The ACSA Code of Conduct aims to define a set of values and standards to which custodians are expected to adhere; seeks to strengthen good relations between custodians and their clients; to promote good business practices and minimum standards of behaviour expected by the financial services industry; and to foster good conduct and market practice.

Member Responsibilities

Members should conduct their activities with the highest degree of integrity and fair dealing to ensure that: 

  • Client interests are considered in all operational decisions and processing; 
  • Their conduct contributes to markets operating in an efficient, fair and informed manner.  

Member custodians must:

  • Observe the financial requirements of the relevant regulator (i.e. Australian regulators such as ASIC or APRA; or foreign regulators such as the Financial Services Authority (UK)); 
  • Maintain appropriate compensation arrangements which may include insurance cover for infidelity of employees, electronic and computer crime, forgery and fraud that a prudent person providing such custodial services would hold; 
  • Comply with financial services laws as defined by the Corporations Act 2001; and 
  • Not employ disqualified persons in responsible positions. 

Privacy and use of confidential information

Confidentiality is essential for the preservation of industry and client reputations. Member custodians must take reasonable steps to ensure that confidential information on clients or their dealings are not disclosed, nor pressure applied on others to disclose such information except in strict accordance with the exceptions recognised by law or the terms of the applicable contract. Member custodians should strive to ensure that all relevant staff observe this fundamental principle.


ACSA is conscious of its obligations to comply with all relevant legislation affecting its operations. Members are required at all times to act with due skill, care and diligence and maintain relevant standards of competence. They should ensure that employees are competent to perform the tasks they undertake in the operation of their member’s business. Where relevant, members should ensure employees have:

  • A commitment to updating professional knowledge to keep abreast of industry developments and trends; and
  • Appropriate education by either relevant formal qualifications and/or structured and documented internal or external training, and/or relevant work experience.

Members are required to comply with the relevant law and to cooperate with regulators in connection with enforcement of the relevant law. Members shall cooperate with clients and agents or other representatives to facilitate the client’s compliance with the law as it relates to the use of professional custody services. Member custodians must take all reasonable steps to ensure that staff are fully informed of, and comply with, this Code and all relevant laws and ethical standards applying to their activities in the market. Staff should be made aware of improper conduct and be encouraged to report to their superiors any such conduct by other staff. 


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