Leave More Leeway for Contractual Freedom

The European Securities and Markets Authority ESMA has consulted on a Code of Conduct for issuer-paid research. As this draft is based exclusively on French models, we suggest that voluntary codes of conduct from other countries should also be taken into account. For Germany, this would be the German Principles for Financial Research, which have also been recognised as best practice by BaFin. We also recommend that the Code of Conduct be kept as flexible as possible, for example by not having a specific remuneration structure.