Breaking Silos and Building Trust: Lessons from the South African Market Surveillance Code of Conduct

The discussion opened with a fundamental question: What does market integrity mean in today’s South African capital markets?

For Happy Shihau, it’s non-negotiable. “At the very core of what we do is underpinned by ethical standards,” she emphasized. The new code, she explained, is a product of deep industry collaboration that was crafted through ongoing dialogue with stakeholders across the financial ecosystem.
 

Themba Maseko echoed this sentiment, defining market integrity simply as “doing what is right, even when no one is watching.” His call to return to basics, such as building systems and processes that enable ethical behavior, underscored the code’s foundational purpose: to create a culture of accountability that transcends individual firms and resonates across the global financial landscape.
 

What sets this initiative apart is its grassroots origin. Nasdaq’s role was not to impose a top-down solution, but to support a bottom-up movement. “What I love about what they’re doing is that it’s a grassroots effort,” Tony Sio said. “It incorporated everyone in the financial community.”

This inclusive approach is what gives the code its strength. It’s not a one-size-fits-all framework imported from abroad, but a locally tailored solution informed by international best practices. The result is a code that is both globally relevant and locally appropriate—a rare balance in the world of financial regulation.
 

One of the most powerful themes to emerge from the discussion was the idea that compliance is a collaborative space. In an industry where firms often guard their strategies closely, the development of the code represents a shift toward openness and shared responsibility.

“We are all competitors in terms of a commercial perspective, […] selling financial services and financial products. But the beauty in the compliance and regulatory space is that it’s a noncompetitive environment. This is a place where we can actually bring our ideas and thoughts together to make sure that collectively, we move the dial so we can work with our regulators and our peers in a noncompetitive way,” said Happy Shihau. This mindset has enabled robust conversations and honest engagement, ultimately leading to a code that reflects the collective wisdom of the industry.

Themba Maseko added that the code’s success hinged on a shared vision: “We all want to be part of a winning financial market. You can’t win alone in a market that’s not adopting best principles.” This sense of shared destiny has been instrumental in securing buy-in from regulators, exchanges and firms of all sizes.
 

A key challenge in developing the code was ensuring that it would be accessible and applicable to all market participants, regardless of size or resources. South Africa’s financial landscape includes a wide range of firms, from large institutions to small brokers, and the code needed to reflect that diversity.

To address this, the code was designed with flexibility in mind. It allows for scalable implementation, ensuring that even firms with limited budgets can build effective internal frameworks for market surveillance. This democratization of compliance is a critical step toward leveling the playing field and fostering a more inclusive financial ecosystem.
 

As Tony Sio pointed out, “You can’t just take global standards, no matter how good they are, and ram them down into any marketplace.” Instead, the focus was on creating solutions that are “fit for purpose,” tailored to the unique challenges and opportunities of the South African market.
 

Beyond the technical aspects of surveillance, the panelists emphasized the importance of culture in driving meaningful change. Breaking down silos between compliance, technology and front-office teams requires a shift in mindset.

“Everyone in the organization needs to understand that this is important. When we engage with an organization, we try and engage with everyone across the compliance and trading functions, across everyone within the organization—because everyone needs to be brought in,” said Tony Sio. He stressed the need for cross-functional engagement, where all departments are aligned around a shared commitment to integrity.
 

This cultural alignment enables organizations to move from compliance as a checkbox exercise to compliance as a strategic advantage. It’s also what allows for the kind of deep collaboration that has defined the development of the South African Market Surveillance Code of Conduct.
 

Trust emerged as a central theme throughout the conversation. In a globalized financial system, trust is the currency that underpins investment, growth and resilience. For emerging markets like South Africa, demonstrating credibility on the global stage is essential.

The South African Market Surveillance Code of Conduct is a powerful signal to international investors that South Africa is serious about market integrity. It shows that the country’s financial institutions are not only aware of global best practices but are actively working to implement them in a way that reflects local realities.

As Themba Maseko put it, “When investors look at the South African financial market, they need to have trust that if we send our investment there, there’s credibility.”
 

Perhaps the most poignant moment of the discussion came when Happy Shihau invoked the South African philosophy of “ubuntu,” a concept that emphasizes shared humanity and collective progress. “There’s a term called ubuntu, and that’s really working together,” she said. “This has been an indicator of the power that comes with collaboration across the entire value chain.”

This spirit of ubuntu is what has made the South African Market Surveillance Code of Conduct a symbol of what’s possible when an industry comes together with a shared purpose.
 

The launch of the South African Market Surveillance Code of Conduct serves as a model for how financial markets around the world can build trust, transparency and resilience through collaboration. By prioritizing ethical standards, embracing inclusive design and fostering a culture of shared responsibility, South Africa’s financial community has taken a significant step forward. With partners like Nasdaq supporting the journey, the path ahead looks not only promising but transformative.