Exhibit 11.1 Regulatory Compliance Operational Policy Market Abuse & Inside Information Chapter 5 – PAD 1

Minimum Standards At a glance…’what’ needs to be considered? The purpose of this operational policy is to ensure that all staff and their Closely Associated Persons (CAPs) comply with their obligations in relation to personal account dealing, that is personal trading in financial instruments (for example, shares and corporate bonds). Protecting the integrity of financial markets is critical to promoting fair and efficient markets and investor confidence. The regulatory framework is designed to ensure a level playing field where everyone trading in financial markets has access to the same information and those with confidential or inside information do not inappropriately use this for their personal advantage. Failure to comply with this Policy can have serious consequences for the Group, its Staff and customers and, in some circumstances, can be a criminal offence called ‘insider dealing’. Insider dealing is punishable by a fine and/or imprisonment. Individuals may also be banned from working in the financial services industry All Staff must be aware of this Policy and understand their personal responsibilities under it by - undertaking training on personal account dealing as part of their induction - PDMRs, NWG, NWM and NWM NV Insiders and Staff designated as Private Side or with a Special Status undertaking regular on-going training This Operational policy makesreference to in-scope colleagues, contractors, agency staff and their CAPs. These are defined as: - Staff designated as Public side - Persons Discharging Managerial Responsibility ('PDMRs') - NWG permanent Insiders and Staff at higher risk of handling Group Inside Information - Staff designated as Private Side and Staff designated with a Special Status FFLEs may mandate additional requirements for their Staff over and above these minimum requirements. Where this applies, FFLEs must: - provide detailsto the Control Room; - create, document and maintain local personal account dealing procedures; - communicate the requirements to impacted Staff; and - oversee their Staff’s compliance with local procedures.

Mandatory Requirements Building upon the high-level key control requirements within the L2 MARII Risk Standard, we clarify below the mandatory requirements to be in place. General Staff Requirements What All in scope permanent colleagues, contractors, agency staff and their CAPs must receive trading approval prior to placing instructions in financial instruments. All in scope permanent colleagues, contractors, agency staff and their CAPs will be prevented from trading where inside information for the issuer wishing to be traded is held within NatWest Group (Via use of PAD system). Why By seeking approval prior to executing a trade, approval will not be granted where inside information is held for the financial instrument be requested to trade. How i. FFLEs must ensure staff do not undertake personal account dealing if this would create a potential or actual conflict of interest or detract from their ability to carry out their role within the Group. This includes, but is not limited to, Staff being in receipt of inside information about the issuer ii. Other than in the normal course of their employment, FFLEs must ensure Staff do not advise, encourage or recommend any person to undertake personal account dealing, if they would not be permitted to undertake it themselves. iii. FFLEs must ensure their staff personal account dealing does not involve: - shortselling activity - excessive risk - financialspread-betting Persons Discharging Managerial Responsibility ('PDMRs') - PDMRs are notified of their status by Legal, Governance & Regulatory Affairs(LG&RA) What Prior to all in scope permanent colleagues, contractors, agency staff and their CAPs being allowed to trade, we must ensure all designated permanent colleagues, contractors, agency staff and their CAPs have disclosed their broker accounts. Why With all in scope permanent colleagues, contractors, agency staff and their CAPs disclosing their brokerage accounts, via monitoring, we can ensure that no unauthorised trading within financial instruments are executed by those where inside information is held, that would result in insider dealing.

How i. FFLEs must ensure Staff disclose any in scope brokerage accounts (as defined in Appendix B) that they and/or their CAPs hold which allow personal account dealing in Financial Instruments(as defined the non-exhaustive list in Appendix A). CAPs are defined as: - any spouse/partner - dependent children - family members who have lived with the Staff member for at least 12 months - any other individual over whose accountsthe Staff member has control or influence (for example, via a power of attorney) It can also include a company, trust or partnership controlled or managed by, or set up for the benefit of, an employee or director, or one of their CAPs. Staff must ensure that their CAPs are aware that information relating to them and their personal account dealing is stored by the Group on our PAD System. A factsheet for CAPS is available via the Control Room PAD webpage. NB: The rules relating to CAPs do not apply to staff based permanently or temporarily in Germany, or those employed by a legal entity established in Germany except where the CAP is acting under instructions from, or on behalf of the employee. What All in scope permanent colleagues, contractors, agency staff and their CAPs must receive approval prior to placing instructions in financial instruments. All in scope permanent colleagues, contractors, agency staff and their CAPs will be prevented from trading where inside information for the issuer wishing to be traded is held within NatWest Group (Via use of PAD system). Why By seeking approval prior to executing a trade, approval will declined via the PAD system where inside information is held for the financial instrument be requested to trade. How ii. FFLEs must ensure Staff do not undertake personal account dealing if this would create a potential or actual conflict of interest or detract from their ability to carry out their role within the Group. This includes, but is not limited to, Staff being in receipt of Inside Information about the issuer iii. Other than in the normal course of their employment, FFLEs must ensure Staff do not advise, encourage or recommend any person to undertake personal account dealing, if they would not be permitted to undertake it themselves. iv. FFLEs must ensure their Staff personal account dealing does not involve: - shortselling activity - excessive risk - financialspread-betting v. FFLEs must ensure in-scope Staff complete the PAD attestation within 30 days of joining their role and annually thereafter vi. FFLEs must ensure that in-scope Staff And their CAPs obtain approval from their Line Manager and via the Personal Account Dealing System (‘PAD System’) when required, prior to dealing. vii. FFLEs must ensure Staff use the PAD system to make disclosures unless they are a PDMR

without access(see the below table for PDMRs without PAD access). viii. FFLEs must ensure any PDMRs personal account dealing in Group Financial Instruments complies with the Executive Shareholding Requirements. ix. FFLEs must ensure PDMRs personal account dealing in Group Financial Instruments is notified to LG&RA within 2 business days of executing the transaction. LG&RA will then notify the regulator of the transaction. x. FFLEs must ensure Staff adhere to the decision of the Control Room. xi. FFLEs must ensure Staff make arrangements for their and/or their CAPs broker(s) to provide the Control Room with copies of their trade confirmations. Where this cannot be facilitated, Staff must provide the confirmations within 30 days of the date of the transaction. xii. FFLEs must ensure Staff hold Financial Instruments for a minimum of 30 days, unless advised otherwise, to avoid the appearance ofspeculative trading or trading for short term gain. Approval Requirements PDMRs who are also Permanent Insiders or at higher risk of handling NWG Inside Information xiii. FFLEs must ensure Staff and their CAPs do not undertake any personal account dealing in Group Financial Instruments during any period of time designated as a ‘closed window’. General exceptions are set out in appendix C. For Line Managers xiv. FFLEs must ensure line Managers review and respond to approval requests from their in- scope Staff. Before Lpproving a request, Line Managers must determine that: - the proposed transaction would not breach this Policy or any local (country specific) restrictions, particularly any applicable sector and/or instrument coverage prohibitions; - the proposed transaction would not cause an actual or potential/perceived conflict of interest with the Staff member's role; - the size and nature of the proposed transaction (and itsrelationship to previous transactions) isreasonable for the Staff member; NatWestGroup PDMR Role Approvalto be sought from (Primary Approver) Approvalto be sought from (Alternative Approver) Disclosure to / Approval from NWG / NWH Chairman NWG / NWH CEO NWG / NWH Senior IndependentDirector Emailrequest to PADUK NWG /NWHExecutive Directors NWG / NWH Chairman NWG / NWH Senior IndependentDirector Emailrequestto PADUK NWG / NWH Non-ExecutiveDirectors NWG / NWH Chairman NWG /NWHCompany Secretary Emailrequestto PADUK NWG ExCo Members (other than Executive Directors) NWG CEO NWGCompany Secretary PAD System NWHExCo Members, NWM CEO and RBSI CEO NWG / NWH CEO (or Line Managerif different) NWG /NWHCompany Secretary PAD System Designation NWG Financial Instrument Non-NWGFinancial Instrument PDMR, PermanentInsider and those at high risk of handling Group Inside Information Yes No (Unless designated private side and/orspecialstatus)

- the Staff member and their department is not currently and/or does not expect to be involved in a significant transaction relating to the issuer or be otherwise in receipt of inside information; - the frequency of transactions undertaken by the Staff member is reasonable - their personal account dealing is not interfering with the performance of their work-related duties; - the personal account dealing does not involve excessive risk. xv. FFLEs must ensure line Managersseek guidance from the Control Room if they are unsure of the correct course of action or there are any potential issues/concerns. xvi. Line Managers who are aware or suspect that a member of their Staff is in breach of this Policy must promptly report this to the Control Room. What PAD surveillance covering all in scope permanent colleagues, contractors and agency staff is designed, maintained, and deployed, together with at least annualreview,to detect instances of unapproved personal trading. Why Surveillance is required to detect all in scope permanent colleagues, contractors and agency staff who have disclosed their brokerage accounts trading without seeking prior approval do to so, potentially highlighting staff trading on inside information How xvii. FFLEs must ensure the following in-scope staff subject to any of the below are subject to surveillance: - disclosure of broker accounts - PAD attestation - PAD approval - broker confirmations - minimum holding periods NWG permanent Insiders and Staff at higher risk of handling Group inside information NWG Insiders and staff at higher risk are notified of their status by the Control Room What Prior to all in scope permanent colleagues, contractors, agency staff and their CAPs being allowed to trade, we must ensure all designated permanent colleagues, contractors, agency staff and their CAPs have disclosed their broker accounts. Why With all in scope permanent colleagues, contractors, agency staff and their CAPs disclosing their brokerage accounts, via monitoring, we can ensure that no unauthorised trading within financial instruments are executed by those where inside information is held, that would result in insider dealing. How

i. FFLEs must ensure Staff must disclose any in scope brokerage accounts (as defined in Appendix B) that they and/or their CAPs hold which allow personal account dealing in Financial Instruments (as defined in Appendix A). CAPs are defined as: - any spouse/partner - dependent children - family members who have lived with the Staff member for at least 12 months - any other individual over whose accountsthe Staff member has control or influence (for example, via a power of attorney) It can also include a company, trust or partnership controlled or managed by, or set up for the benefit of, an employee or director, or one of their CAPs. Staff must ensure that their CAPs are aware that information relating to them and their personal account dealing is stored by the Group on our PAD System. A factsheet for CAPS is available via the Control Room PAD webpage. NB: The rules relating to CAPs do not apply to staff based permanently or temporarily in Germany, or those employed by a legal entity established in Germany except where the CAP is acting under instructions from, or on behalf of the employee. All in scope permanent colleagues, contractors, agency staff and their CAPs must receive approval prior to placing instructions in financial instruments. All in scope permanent colleagues, contractors, agency staff and their CAPs will be prevented from trading where inside information for the issuer wishing to be traded is held within NatWest Group (Via use of PAD system). Why By seeking approval prior to executing a trade, approval will declined via the PAD system where inside information is held for the financial instrument be requested to trade. How ii. FFLEs must ensure staff do not undertake personal account dealing if this would create a potential or actual conflict of interest or detract from their ability to carry out their role within the Group. This includes, but is not limited to, Staff being in receipt of inside information about the issuer iii. Other than in the normal course of their employment, FFLEs must ensure Staff do not advise, encourage or recommend any person to undertake personal account dealing, if they would not be permitted to undertake it themselves. iv. FFLEs must ensure their staff personal account dealing does not involve: - shortselling activity - excessive risk - financialspread-betting v. FFLEs must ensure in-scope Staff complete the PAD attestation within 30 days of joining their role and annually thereafter vi. FFLEs must ensure that in-scope Staff And their CAPs obtain approval from their Line Manager and via the Personal Account Dealing System (‘PAD System’) when required, prior to dealing. vii. FFLEs must ensure Staff use the PAD system to make disclosures viii. FFLEs must ensure Staff adhere to the decision of the Control Room.

ix. FFLEs must ensure Staff make arrangements for their and/or their CAPs broker(s) to provide the Control Room with copies of their trade confirmations. Where this cannot be facilitated, Staff must provide the confirmations within 30 days of the date of the transaction. x. FFLEs must ensure Staff hold Financial Instruments for a minimum of 30 days, unless advised otherwise, to avoid the appearance ofspeculative trading or trading for short term gain. Approval Requirements PDMRs who are also Permanent Insiders or at higher risk of handling NWG Inside Information xi. FFLEs must ensure Staff and their CAPs do not undertake any personal account dealing in Group Financial Instruments during any period of time designated as a ‘closed window’. General exceptions are set out in appendix C. For Line Managers xii. FFLEs must ensure line Managers review and respond to approval requests from their in- scope Staff. Before approving a request, Line Managers must determine that: - the proposed transaction would not breach this Policy or any local (country specific) restrictions, particularly any applicable sector and/or instrument coverage prohibitions; - the proposed transaction would not cause an actual or potential/perceived conflict of interest with the Staff member's role; - the size and nature of the proposed transaction (and itsrelationship to previous transactions) is reasonable for the Staff member; - the Staff member and their department is not currently and/or does not expect to be involved in a significant transaction relating to the issuer or be otherwise in receipt of inside information; - the frequency of transactions undertaken by the Staff member is reasonable - their personal account dealing is not interfering with the performance of their work-related duties; - the personal account dealing does not involve excessive risk. xiii. FFLEs must ensure line Managersseek guidance from the Control Room if they are unsure of the correct course of action or there are any potential issues/concerns. xiv. Line Managers who are aware or suspect that a member of their Staff is in breach of this Policy must promptly report this to the Control Room. What PAD surveillance covering all in scope permanent colleagues, contractors, agency staff and their CAPs designed, maintained, and deployed, together with at least annual review, to detect instances of unapproved personal trading. Why Designation NWG Financial Instrument Non-NWGFinancial Instrument PDMR, PermanentInsider and those at high risk of handling Group Inside Information Yes No (Unless designated private side and/orspecialstatus)

Surveillance isto detect all in scope permanent colleagues, contractors, agency staff and their CAPs who have disclosed their brokerage accounts trading without seeking prior approval do to so, potentially highlighting staff trading on inside information How xv. FFLEs must ensure the following in-scope staff subject to any of the below are subject to surveillance: - disclosure of broker accounts - PAD attestation - PAD approval - broker confirmations - minimum holding periods Staff designated as Private side or with a special status Aslisted on the Staff members ECD Profile What Prior to all in scope permanent colleagues, contractors, agency staff and their CAPs being allowed to trade, we must ensure all designated permanent colleagues, contractors, agency staff and their CAPs have disclosed their broker accounts. Why With all in scope permanent colleagues, contractors, agency staff and their CAPs disclosing their brokerage accounts, via monitoring, we can ensure that no unauthorised trading within financial instruments are executed by those where inside information is held, that would result in insider dealing. How i. FFLEs must ensure Staff must disclose any in scope brokerage accounts (as defined in Appendix B) that they and/or their CAPs hold which allow personal account dealing in Financial Instruments (as defined in Appendix A). CAPs are defined as: - any spouse/partner - dependent children - family members who have lived with the Staff member for at least 12 months - any other individual over whose accountsthe Staff member has control or influence (for example, via a power of attorney) It can also include a company, trust or partnership controlled or managed by, or set up for the benefit of, an employee or director, or one of their CAPs. Staff must ensure that their CAPs are aware that information relating to them and their personal account dealing is stored by the Group on our PAD System. A factsheet for CAPS is available via the Control Room PAD webpage. NB: The rules relating to CAPs do not apply to staff based permanently or temporarily in Germany, or those employed by a legal entity established in Germany except where the CAP is acting under instructions from, or on behalf of the employee. What All in scope permanent colleagues, contractors, agency staff and their CAPs must receive trading approval prior to placing instructions in financial instruments.

All in scope permanent colleagues, contractors, agency staff and their CAPs will be prevented from trading where inside information for the issuer wishing to be traded is held within NatWest Group (Via use of PAD system). Why By seeking approval prior to executing a trade, approval will declined via the PAD system where inside information is held for the financial instrument be requested to trade. How ii. FFLEs must ensure staff do not undertake personal account dealing if this would create a potential or actual conflict of interest or detract from their ability to carry out their role within the Group. This includes, but is not limited to, Staff being in receipt of inside information about the issuer iii. Other than in the normal course of their employment, FFLEs must ensure Staff do not advise, encourage or recommend any person to undertake personal account dealing, if they would not be permitted to undertake it themselves. iv. FFLEs must ensure their staff personal account dealing does not involve: - shortselling activity - excessive risk - financialspread-betting v. FFLEs must ensure in-scope Staff complete the PAD attestation within 30 days of joining their role and annually thereafter vi. FFLEs must ensure that in-scope Staff And their CAPs obtain approval from their Line Manager and via the Personal Account Dealing System (‘PAD System’) when required, prior to dealing. vii. FFLEs must ensure Staff use the PAD system to make disclosures viii. FFLEs must ensure Staff adhere to the decision of the Control Room. ix. FFLEs must ensure Staff make arrangements for their and/or their CAPs broker(s) to provide the Control Room with copies of their trade confirmations. Where this cannot be facilitated, Staff must provide the confirmations within 30 days of the date of the transaction. x. FFLEs must ensure Staff hold Financial Instruments for a minimum of 30 days, unless advised otherwise, to avoid the appearance ofspeculative trading or trading for short term gain. Approval Requirements Designation NWG Financial Instrument Non-NWGFinancial Instrument Private Side and/or Special Status No – unless designated a NWG or higher risk of handing Group Inside Information Insider Yes For Line Managers xi. FFLEs must ensure line Managers review and respond to approval requests from their in- scope Staff. Before approving a request, Line Managers must determine that: - the proposed transaction would not breach this Policy or any local (country specific) restrictions, particularly any applicable sector and/or instrument coverage prohibitions; - the proposed transaction would not cause an actual or potential/perceived conflict of interest with the Staff member's role; - the size and nature of the proposed transaction (and itsrelationship to previous

transactions) isreasonable for the Staff member; - the Staff member and their department is not currently and/or does not expect to be involved in a significant transaction relating to the issuer or be otherwise in receipt of inside information; - the frequency of transactions undertaken by the Staff member is reasonable - their personal account dealing is not interfering with the performance of their work-related duties; - the personal account dealing does not involve excessive risk. xii. FFLEs must ensure line Managersseek guidance from the Control Room if they are unsure of the correct course of action or there are any potential issues/concerns. xiii. Line Managers who are aware or suspect that a member of their Staff is in breach of this Policy must promptly report this to the Control Room. What PAD surveillance covering all in scope permanent colleagues, contractors, agency staff and their CAPs designed, maintained, and deployed, together with at least annual review, to detect instances of unapproved personal trading. Why Surveillance isto detect all in scope permanent colleagues, contractors, agency staff and their CAPs who have disclosed their brokerage accounts trading without seeking prior approval do to so, potentially highlighting staff trading on inside information How xiv. FFLEs must ensure the following in-scope staff subject to any of the below are subject to surveillance: - disclosure of broker accounts - PAD attestation - PAD approval - broker confirmations - minimum holding periods

Appendix A: Financial Instruments in and out of scope of requiring pre-approval The list below is non exhaustive. If an investment is not listed, contact the PAD team to clarify if pre- approval is required. Financial Instruments In or out ofscope of requiring approval Prohibited 1) Uncovered Options N/A Yes 2) Spread betting – All financial contracts, including single stock, indices, Interest Rates, Currencies and Commodities N/A Yes 3) Short Selling N/A Yes 4) Equity and derivatives (listed and private companies): a) Shares b) Options c) Futures d) Forwards e) Swaps f) Contractsfor Differences g) Initial Public Offerings h) Corporate Actions/RightsIssues i) Equity Derivatives j) American Depository Receipts(ADRs) k) Global Depository Receipts(GDRs) l) Asset Backed Security (ABS) m) Warrants In Scope No 5) Debt and derivatives(listed and private companies): a) Corporate, government, Sovereign,supranational, municipal, treasury (excluding G7) Bonds b) Futures c) Exchangeable and Convertible d) Fixed Income Derivatives e) Fixed Income Futures f) Tradeable Loans g) Warrants In Scope No 6) Commodities on single stocks only: a) Options b) Futures c) Forwards d) Swaps e) Warrants In Scope No 7) Currencies(including crypto currency): a) Options In Scope No

b) Futures c) Forwards d) Swaps e) Warrants f) Interest Rate Derivatives 8) Funds: a) Narrow Based Exchange Traded Funds (where there are no more than 20 underlying holdings or at least one holding makes up 20% of that fund) b) Investment Trusts/Closed Ended Investment Companies c) Leveraged Exchange Traded Funds(ETFs) In Scope No 9) Private Investments: a) Enterprise Investment Schemes b) Venture Capital Trusts c) Hedge Funds d) Peer-to-peer funding – where you know the name of the company you are investing in e) Crowd funding – where you are investing in a company and getting a financial return f) Notes and Structured Productslinked to Private Investments, EIS, VCT and Hedge Funds In Scope No 10) Successive transactions: a) Successive transactions which are unchanged, such as regular monthly investments, where permission has been soughtfor the initial investment (Note: Staff must be clear when seeking permission that it will be a recurring transaction) b) Cancellations ofsuccessive transaction instructions, providing there is no disposal of any holding atthe same time Out of Scope No 11) Investmentsinto open ended Collective Investments Schemes Out of Scope No 12) Investmentsinto G7 Government Bonds, unlessrole-specific restrictions apply Out of Scope No 13) Investmentsinto index or tracker funds Out of Scope No 14) Crowd funding – where you are pre-ordering a physical product or service Out of Scope No 15) Peer-to-peer funding – the peer-to-peer company investin a number of different investments on your behalf, you are unaware of the companies / individuals and have no control over this Out of Scope No Appendix B: Brokerage Accounts The following types of accounts are in scope (whether active or dormant) and need to be disclosed: i. accounts with brokerage capability that can execute transactionsin one or more Financial Instruments; ii. brokerage accounts in which the Staff member/their CAP has an economic interest and/or the power, directly or indirectly, to make or influence investment decisions (for example, the Staff member is acting as a trustee or under a Power of Attorney. iii. brokerage accounts administrated / managed by an Independent Financial Advisor or Wealth Manager where the Staff member/their CAP are involved in and/or have discretion about investment decisions.

The following types of account are out of scope and do not need to be disclosed: i. discretionary accounts where the Staff member/their CAP hasfully delegated the investment decision-making to a third party (for example, via a written discretionary investment management agreement); ii. current, checking, savings, money market, cash-only ISAs and other deposit accounts without brokerage capabilities; iii. open-ended investment companies and unit trusts held directly at the fund distributor that are restricted solely to mutual funds or money market investments; iv. managed savings and collective investment planssuch as pensions (provided that individual investment decisions cannot be taken by the account holder); and v. loan accounts(for example, credit cards or mortgages). vi. Nominee Accounts holding NWG securitiesreceived under a NWG Employee Share Plan vii. Nominee Accounts holding securitiesreceived under previous employment Share Scheme, for in- scope Staff, the sale would require approval prior to selling. Appendix C: General Exceptions for PAD in Group Financial Instruments Whatshare plan activitiesrequire pre-approval under this operating policy? BAYE Employee Share Plan Deferral Plan Long-term incentive awards Sharesave 1) Joining a Group Share Plan or accepting the grant of an award under it N N N N N 2) Receiving sharesfollowing the end of a retention period N N N N N 3) Gift, loan, assignment charge or pledge of any Group securities which are the subject of an award Y Y Y Y Y 4) Vesting of an award or an allowance N N N N N/A 5) Using your savings to exercise a Sharesave option (without immediate sale of the shares). Although pre-approval is not required, NWG Insiders and PDMRs cannot exercise a Sharesave option, in the 30 days prior to the announcement of the Group’s full or half year financialresults N/A N/A N/A N/A N 6) Varying or cancelling monthly contribution amounts although pre-approval is not required, NWG Insiders and PDMRs cannot join, vary, or cancel BAYE contributions, or in the 30 days prior to the announcement of the Group’sfull or half year financialresults N N/A N/A N/A N 7) Transfer of shares to an ISA N Y Y Y N 8) Transfer of shares where no change in beneficial ownership and no associated sale transaction N N N N N

9) Selling Group Shares acquitted under a Group share plan (includes advanced elections and shares acquired via Sharesave). Although such sales need to be pre- approved, they do not need to comply with the 30-day minimum holding period requirement Y Y Y Y Y 10) Automatic sale ofsharesto satisfy a tax liability N N N N N Mandatory Requirement Applicable Rule References Applicable Rule References Market Abuse Directive (MAD) EU/UKMarket Abuse Regulation (MAR) Article 7, Inside Information Article 8, Insider dealing Article 10, unlawful disclosure of inside information Article 14, Prohibition of insider dealing and of unlawful disclosure of inside information Article 16, Prevention and detection of market abuse Article 16.5 Market Abuse Regulatory Technical Standard FCA Market Abuse Handbook SYSC Chapter 6.1 SYSC Chapter 10A

Further Information Need more information? For more information, please see: • Conduct Policy (L1) • Market Abuse & Inside Information Risk Standard (L2) • Market Abuse & Inside Information Regulatory ComplianceOperating Policies • Information Security – Information Classification • Data Leakage • Non-Financial Risk toolkit • Compliance Handbook Documentation control & key contacts Date of Issue 16.05.2023 Version 2.0 Regulatory Compliance Operational Policy SME Mike Davis Approved By Es Nelson-Jones Approved Date 12.05.2023 Market Abuse Requirements Regulator/Regulation Section Associated Requirement PrinciplesforBusiness (PRIN) 2.1 The FCA Principles are a general statement of the fundamental obligations of firms and the other persons to whom they apply under the regulatory system. Notable principles aligned to this Standard are: 1 – Integrity, a firm must conduct its business with integrity. 2 – Skill, care and diligence, a firm must conduct its business with due skill, care and diligence. 3 – Management and control, a firm must take reasonable care to organise and control its affairs responsibly and effectively, with adequate risk management systems. 5 – Market conduct, A firm must observe proper standards of market