Undertakings for Collective Investment in Transferable Securities (UCITS) IV raised much industry debate prior to its introduction on July 1, 2011 across a number of areas.  Now, with the opportunity to begin assessing its implications in practice, it is likely that this debate will continue.  One area that is receiving increasing focus is the MiFID-esque conduct of business rules imposed on UCITS management companies (and self-managed UCITS) under the UCITS IV Management Company Directive.  In almost all cases at present, UCITS management companies (and self-managed UCITS) fully outsource the asset management function to one or more investment management firms.  These firms are now finding themselves directly subject to UCITS IV conduct of business rules.  So just how much will UCITS IV impact how investment managers manage UCITS?  In this article, Stephen Carty, a partner in the Dublin office of international law firm Maples and Calder, considers the new and enhanced policies and procedures that will be required as well as considering some of the practical implications.  In particular, Carty discusses: UCITS IV rules with respect to best execution, order handling and aggregation, due diligence and voting rights policies; the general absence of carve outs in UCITS IV; the lack of account in UCITS IV for the delegation model typical in the investment management field; and the differences in four important areas between UCITS IV and the MiFID regime.