This makes perfect sense, and one small step in the right direction.
penalty for failure to adopt and execute the code should be substantial enough to ensure rectification of such code & practices, however, this might push big firms with means to look for 'ways around it', one such step could be skip London altogether en mass. (its not likely to happen, but even our great Andy Murray won Wimbledon!)
Therefore, I do not envy position of Martin & Andrew as it is a very finely balanced chess strategic worldwide jurisdictional game on their hands (despite London is a leading player).
Furthermore, same code should also be applicable for major firms whether they are FTSE50/100 or not as the sheer size of such corporations means their success and/or failure would also impact general public on medium/long term also (e.g. most pension funds would be holding BP/Cheveron and Unilever/P&G stocks!)
Internal auditors should definitely be empowered and the most senior should be on the board, but so far, their shouts (if any) have sadly (& could still be) fallen on deaf ears unless the firms are 'locked-in' to execute the code and substantial stick to ensure they perform.
Otherwise, it is like telling kids to monitor their parents...
(PS: some might say slightly simple questions, but who can enforce it, as it is not law but only code!? who judge if they have done according to rules? by the time all these run its course, the firm in question may already be bankrupted or be rescued... hence sadly this is not the overall answers neither!)
BR
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