Three integrity pitfalls putting sustainable finance under pressure

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Sustainability is everywhere in the financial sector – but that doesn’t mean it’s easy to get it right. On the contrary: conversations with professionals reveal that practice often falls short of ambition.

DSI and The Can Do Company spoke with experts from across the sector about the tension between sustainability goals and the realities of day-to-day work. From these conversations, three recurring integrity pitfalls emerged – striking in both their persistence and their familiarity. These have been captured in the dialogue document Between the Lines, designed to raise awareness among professionals and spark honest, constructive conversations.

Three recurring areas of tension

  1. Managing expectations: Who is responsible for driving sustainability – companies, investors, governments? Sustainability may appear measurable and controllable, but system pressures and a false sense of certainty often lead to greenwishing rather than real impact.

  2. Communicating effectively How can we make the trade-offs and complexity of sustainability understandable? More data and more transparency don’t automatically create clarity or sound advice – especially when knowledge gaps stand in the way of meaningful dialogue.

  3. Safeguarding integrity
    How can we prevent rules and regulations from unintentionally blocking real progress? Hopeful slogans and checklist-driven compliance can replace solid reasoning – putting both genuine impact and trust at risk.

What now?
Between the Lines is used as part of DSI’s permanent education programme and as a conversation starter within financial organisations. It is not a conclusion, but an open invitation to reflect and engage.

Want to learn more or connect with the initiators?
Download the document at www.dsi.nl/en/susfin or get in touch with DSI.

What is the sustainable investor really buying: a better world or peace of mind?

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Sustainable finance is booming – but doing the right thing is often more complex than it seems. In this series, DSI invites professionals to share their perspectives on the tensions, dilemmas and unwritten rules within sustainable finance. Each month, we publish a guest column inspired by the converation starter Between the Lines. What patterns do you see? Where do integrity pitfalls arise? And what does it really take to achieve meaningful change in the financial sector?

By Harald Walkate

In recent years, sustainable investing has taken off. Good news, one would think – savers, investors and pension participants clearly want to contribute to a better world.

At the same time, however, we need to ask what investors are actually achieving. Many assume that their money flows directly into companies doing good for people and planet – enabling those companies to do even more good. In sector jargon, this is known as additionality: the idea that your investment causes something to happen that otherwise wouldn’t. In other words, a direct causal link between your investment and positive impact.

The reality is far more complicated. For at least three reasons: (1) Most sustainable funds invest in listed companies – meaning the money goes to the sellers of shares, not the companies themselves. (2) Many sustainability solutions are not (yet) commercially viable, so listed companies – with profit as their core driver – are often unable to deliver them. (3) Many sustainability challenges are systemic. The idea that we can achieve sustainability by simply adding up small improvements by companies and individuals is flawed. Systemic problems require systemic incentives to discourage harmful behaviour and promote better alternatives. And who creates those incentives? That’s right – governments.

Does that make sustainable funds the next toxic product – promising the world while delivering little, and charging high fees along the way? Not necessarily. It depends entirely on what the consumer believes they’re buying.

There are roughly three types of motivation:

(a) Peace of mind – “I don’t want to invest in ‘bad’ companies – tobacco, weapons, fossil fuels. I know this won’t reduce smoking or end wars, and I accept that returns may be lower, but I don’t want to profit from these industries.”
(b) Outperformance – “I believe companies that perform well on sustainability will deliver better financial returns.”
(c) Additionality – “I invest because my money helps realise solutions that otherwise wouldn’t happen. I want my money to make a real-world difference.”

Can these expectations be met? Based on current research, a very rough answer might be:
(a) – very well
(b) – no
(c) – to a very limited extent

But how much do we actually know about what motivates consumers? Surprisingly little. This is an under-researched area, and it’s not a topic that financial institutions tend to explore with clients.

This is precisely why DSI’s Between the Lines initiative is so timely – and so well named. If we want to understand whether consumers get what they think they’re buying, we first need to understand what they believe they’re buying: is it (a), (b) or (c)? Financial institutions must learn to read between the lines. Simply hearing “I want to invest sustainably” is not enough – we must ask what the client believes this will achieve.

There’s another reason why the title hits the mark. Financial institutions today operate in a world full of sustainability regulations – including the EU’s Sustainable Finance Disclosure Regulation (SFDR), which classifies funds according to sustainability characteristics.

And yet these regulations say little to nothing about whether a fund aligns with motivations (a), (b) or (c). That makes it all the more important for financial institutions to engage in meaningful dialogue with clients – to clarify whether they’re seeking higher returns, peace of mind, or real-world change.

DSI’s efforts to spark this conversation couldn’t be more relevant. If done well, our savings could indeed contribute to solving pressing societal challenges. But that will require an honest conversation – about investor motivations, the trade-offs involved in different investment strategies, and when money truly makes a difference.

About the author

Harald Walkate is a senior advisor on sustainable finance, impact investment and blended finance at Route17. He is affiliated with the Blended Finance Lab at the London School of Economics and a senior fellow at the University of Zurich’s Center for Sustainable Finance & Private Wealth. Harald brings a unique combination of strategic insight and deep expertise in impact investing, SDG finance and climate-related topics. He previously held senior roles in corporate strategy, business development and sustainability at major financial institutions and started his career as a lawyer. He is also an active jazz pianist and composer.

SoSecure accredited for the AML Register

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The DSI Accreditation Committee has officially accredited the Anti-Money Laundering training offered by SoSecure for the DSI AML Register. This means the programme meets the quality standards DSI sets for professionals in the fields of Anti-Money Laundering (AML) and Customer Due Diligence (CDD). With this recognition, SoSecure joins other accredited providers such as ACAMS, VU Amsterdam and NCI.

About the training

The DSI AML Register recognises professionals with demonstrable expertise in AML through an independent, public register. Employers and clients can rely on the fact that registered professionals meet high standards of quality and integrity. For more information about the register, visit www.dsi.nl/aml.

The training starts in October 2025 and is delivered by experienced professionals from the field. It offers participants a strong foundation and in-depth knowledge on Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT). More information is available on the SoSecure website: www.sosecure.nl/anti-money-laundering.

An overview of all accredited AML training providers can be found here. For questions or additional information, feel free to contact DSI or SoSecure.

DSI Appeal Committee Ruling

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DSI appeal against Disciplinary Committee ruling on illegal investment services by certified professional upheld, but no sanction imposed.

On 30 April 2025, the DSI Appeal Committee issued its ruling in a case involving a former employee of an investment firm, who served as a Senior Investment Manager.

The appeal concerned a review of the Disciplinary Committee’s decision dated 27 August 2024. In that decision, the Committee upheld a complaint from DSI regarding an allegation of conflict of interest involving the certified professional.

Article 7.1.8 of the Code of Conduct: DSI Core Principle 7 – Be clear about interests

The other complaints brought by DSI were dismissed. The Disciplinary Committee chose not to impose any sanctions on the respondent.

DSI raised three grounds of appeal against this ruling. First, DSI argued that the Disciplinary Committee should have ruled on whether the certified professional engaged in secondary activities in violation of DSI’s Code of Conduct. Secondly, DSI claimed the Committee made an incorrect decision on whether the certified professional provided investment services through his private company without holding an AFM licence. Finally, DSI contended that no sanction was wrongly imposed.

The DSI Appeal Committee found the second ground of appeal to be valid and upheld the complaint regarding the provision of illegal investment services through the certified professional’s private company.

Articles 7.1.5 and 7.1.6 of the Code of Conduct: DSI Core Principle 5 – Comply with Rules

The remaining grounds of appeal were rejected. Like the Disciplinary Committee, the Appeal Committee decided not to impose any sanction on the certified professional.

Educational measure imposed by DSI for suspected market manipulation

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On 14 January 2025, DSI imposed an educational measure on a DSI certified investment specialist. The decision followed a transaction involving a suspected case of market manipulation. According to DSI, the professional’s actions were not in line with the DSI Code of Conduct.

What happened?

DSI’s investigation revealed that the certified professional received a client order to purchase shares, with a comment suggesting an anticipated price increase. The order was passed on to another institution responsible for execution. However, a staff member at that institution informed the professional that the order was refused based on advice from their compliance department, due to concerns over potential market manipulation.

Despite this refusal, the certified professional went on to execute the order independently using the trading system of their own employer.

Why does this breach the Code of Conduct?

DSI considers that the combination of the client’s specific request and the compliance warning from the executing institution should have prompted the professional to act with greater caution. Instead of proceeding directly, they should have consulted their own compliance officer before taking further steps. By executing the order without doing so, the professional acted carelessly.

Which rules were breached?

According to DSI, the following articles of the Code of Conduct were violated:

What measure was taken?

When a breach of the Code of Conduct is identified, DSI can impose sanctions. This may involve submitting the case to the DSI Ethics Committee or offering a settlement. In this case, DSI opted for a settlement involving a mandatory training programme. In determining this educational measure, DSI also took into account the employment-related consequences the professional had already faced as a result of the incident.

New at DSI: 10 core principles for professional integrity

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DSI introduces 10 core principles for integrity in action to stimulate dialogue on integrity in the financial sector. The core principles represent the essence of our Code of Conduct. They provide financial professionals with guidance in making the right choices, thus strengthening trust in the sector. Every DSI-certified professional commits to these principles.

What do the core principles mean?

The ten core principles are a practical translation of the DSI Code of Conduct, making it applicable in daily practice. Together, they form a moral compass in situations where laws and regulations do not provide clear answers. This includes ethical dilemmas, gray areas, or rapid changes in the sector.

The principles encourage professionals to think consciously about their actions and to make integrity a constant topic of conversation within teams and management. They provide clear guidelines and directly align with the standards that DSI applies in disciplinary law.

Here are the ten core principles:

  1. Take responsibility – For your own behavior and that of your surroundings.
  2. Focus on the client’s interests – Always act in the best interest of your client.
  3. Act with care – Show respect and expertise in your work.
  4. Show leadership – Promote adherence to the Code of Conduct by others.
  5. Follow the rules – Comply with the rules that apply to your profession.
  6. Ensure confidentiality – Protect confidential information.
  7. Be clear about interests – Prevent conflicts of interest.
  8. Communicate openly – Be transparent and avoid misunderstandings.
  9. Demonstrate expertise – Provide careful and professional advice to your client.
  10. Act honestly – Be ethical and strengthen trust in the market.

These principles are directly linked to the DSI Code of Conduct. A more detailed explanation of the core principles can be found on our website or via this link.

Integrity dilemma? Discuss it or report it to DSI.

Ethical dilemmas should ideally be discussed early within your organization. However, if a situation goes beyond an internal conversation and potentially involves a violation of the Code of Conduct, you can make a report to DSI.

The report will be carefully assessed. If the situation falls under disciplinary law, an investigation will be initiated. The DSI Ethics Committee will hear all involved parties and determine whether a violation has occurred. If so, a sanction may be imposed.

The core principles as a starting point for dialogue

The introduction of these core principles is an invitation to the sector to engage in dialogue about integrity – within teams, with leaders, and with the sector as a whole. By demonstrating leadership, making dilemmas discussable, and acting according to clear principles, we work together towards a transparent and ethical financial sector. The core principles provide direction, but their application requires deeper reflection.

DSI will offer this deeper insight by continuing to engage with the sector on current risks and integrity dilemmas, with a focus on topics such as digitalization and sustainable finance. We will keep you updated on these developments through various media in the coming period.

Rost van Tonningen: “It’s about having the right conversation.”

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Laws and regulations are constantly changing. The context is dynamic. Situations frequently arise where a careful and explainable decision must be made, considering all stakeholders. But how do you put this into practice, especially in the financial sector?

By Roeland Jongejan

According to Françoise Rost van Tonningen, the new chair of DSI’s Integrity Advisory Committee and former Head of the Global Ethics Office (formerly Ethics Office) at Rabobank, integrity is not just about following rules. It is primarily about having the right conversation. “Both complying with regulations and encouraging discussions about dilemmas contribute to creating more ethical organizations.”

Rost van Tonningen takes over the role from Jos Hillen, who has fulfilled the position with dedication in recent years. DSI thanks Jos Hillen for his active contribution, using his knowledge and experience to help advance integrity within the sector.

Françoise Rost van Tonningen, Chair of the DSI Integrity Advisory Committee
Françoise Rost van Tonningen, Chair of the DSI Integrity Advisory Committee

The power of ethical reflection

Rost van Tonningen views integrity and ethics as an ongoing process. “Integrity is about acting honestly, reliably, and responsibly. In addition to complying with laws and regulations, fostering ethical reflection is crucial. It means actively discussing dilemmas and considering moral choices. What is possible and permissible—but is it also desirable? It is precisely in gray areas that organizations have the opportunity to demonstrate their values. This also applies to new developments without a legal framework, where a position still needs to be taken.”

An effective way to strengthen this culture is to encourage dialogue and awareness. “Many organizations have ethics committees and hotlines where employees can seek advice. Additionally, structured approaches, such as dilemma training and case discussions, help employees develop ethical decision-making skills. Prior ethical deliberation, or moral consultation, creates ‘moresprudence’—a valuable collection of insights that guide future decisions on similar issues.”

According to Rost van Tonningen, this approach fosters a more ethical organization. “Not by dictating what is right or wrong, but by facilitating conversations. It is through these discussions that the best course of action becomes clear. By first making all perspectives and arguments explicit, well-considered decisions can be made. Sometimes, this process also reveals that certain policies or procedures are difficult to implement in practice. These conversations help find workable solutions.”

Current challenges: responsible AI and geopolitics

The challenges facing the financial sector have evolved significantly in recent years. Digitalization and responsible AI introduce new ethical questions. “If an investment fund is fully managed by an algorithm, who holds the responsibility? Who asks the ethical questions?”

Geopolitics also plays an increasingly significant role. “Ten years ago, the ethical implications of investments or business presence in certain countries were barely discussed. Now, these issues are firmly on the boardroom agenda. Banks and investment funds must not only consider what is legally possible and permissible, but also what is ethically desirable. This is an ongoing ethical conversation that organizations must engage in.”

Where is the biggest resistance?

Although more companies recognize the importance of integrity, real-world practice remains challenging. “Pressure to meet targets, high workloads, and the drive for commercial success often make it difficult to address ethical dilemmas. If employees are only required to tick boxes, there is little room for reflection. Yet, reflection is essential for making well-informed decisions that can provide financial benefits or positively impact an organization’s reputation.”

Collaboration across departments is crucial. “Different perspectives and responsibilities must be considered. The key is to ensure there are no silos, allowing for a holistic approach to ethical conduct. This is also essential for the organization’s long-term success. To inspire employees, it helps to share best practices.”

DSI’s role: dialogue as the key

Rost van Tonningen sees a vital role for DSI in facilitating discussions on integrity within the financial sector. “DSI is uniquely positioned to bring the industry together. Certification and professional competence provide the foundation, but the real impact comes from creating space for honest conversations about integrity in daily work.”

How does DSI contribute?

“What I appreciate about DSI is that they go beyond certification. Professionals affiliated with DSI are required to complete an integrity module as part of their certification. This ensures that knowledge and experience with integrity dilemmas are not just part of professional competence but also a structured topic of discussion within the industry. That is essential because ‘one individual may be certified and motivated to act with integrity, but if the organizational culture does not support this, it becomes much more difficult,’ says Rost van Tonningen.

Addressing current integrity challenges

She notes that DSI has become increasingly active in facilitating discussions on pressing integrity issues. “Last year, DSI focused on greenwashing, allowing professionals from various sectors to share their experiences and dilemmas. This year, the focus is on sustainable finance and digitalization—topics that are becoming more relevant to financial professionals. I see this as a positive development. There is a lot of discussion about the technology behind digitalization and responsible AI, but ‘there should be more dialogue on the integrity and ethical dilemmas involved. This is both a challenge and an opportunity to implement new technologies responsibly.'”

What should professionals do when they encounteriIntegrity issues?

According to Rost van Tonningen, it is essential for financial professionals to not only know the rules but also understand where to turn when they encounter integrity concerns. “Ideally, ethical dilemmas should be discussed early within an organization, so that a well-reasoned and explainable position can be reached. Prevention is better than cure, and integrity should be a regular topic of discussion within teams and at the board level.”

However, if a situation goes beyond an internal dilemma and may constitute a breach of integrity, financial professionals can report it to DSI. This process follows the DSI Code of Conduct and can lead to disciplinary proceedings. “This not only helps to address misconduct but also strengthens the financial sector as a whole,” says Rost van Tonningen.

A call to action for the sector

Rules and oversight alone are not enough to ensure a sustainable and ethical sector. Rost van Tonningen sees integrity as a shared responsibility between companies, regulators, and organizations like DSI. “We must move beyond simply checking boxes. Integrity is strengthened through open discussions. What seems obvious to you may not be obvious to your colleague. What do we truly value? And how do we ensure we are not just compliant, but also acting ethically?”

Her message to professionals in the sector is clear: “Dare to engage in these conversations. Discuss difficult issues early on, ask questions, and challenge each other to think beyond the letter of the law—if one even exists. Only then can we earn the trust of society as a sector.”

DSI thanks Jos Hillen

With the appointment of Françoise Rost van Tonningen as the new Chair of the Integrity Advisory Committee, DSI bids farewell to Jos Hillen in this role. DSI is grateful for his dedication and active contribution to the work of DSI over the past years, both as a member of the Integrity Advisory Committee and previously as Chair of the DSI Disciplinary Committee. His knowledge and experience have played a key role in strengthening the dialogue on integrity within the financial sector.

New rulings by the DSI Disciplinary Committee

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DSI has recently published two disciplinary rulings. In one case, the DSI Disciplinary Committee upheld a complaint about a conflict of interest involving a Senior Investment Manager but did not impose a sanction. DSI has appealed this decision. In another case, a complaint against an investment advisor for not adhering to the investment policy was dismissed. Read the full article for more details.

DSI complaint on (apparent) conflict of interest upheld, other allegations dismissed

On August 27, 2024, the DSI Disciplinary Committee issued a ruling in a case against a Senior Investment Manager employed by an investment firm.

In its complaint, DSI argued that the certified professional had failed to comply with the internal investment policy of their employer. Additionally, DSI alleged that the respondent had provided investment services through their own company without an AFM license. Finally, DSI pointed out that the respondent had not properly separated their business and personal interests.

The Disciplinary Committee upheld DSI’s complaint regarding the conflict of interest but dismissed the other allegations. The committee decided not to impose a sanction on the certified professional.

DSI has filed an appeal with the DSI Appeals Committee against this ruling.

View the ruling

DSI complaint on non-compliance with investment policy dismissed

On August 27, 2024, the DSI Disciplinary Committee issued a ruling in a case against an investment advisor working as a tied agent for an investment firm. DSI argued in its complaint that the certified professional had failed to comply with the firm’s internal investment policy.

The Disciplinary Committee dismissed DSI’s complaint.

View the ruling

Report integrity issues confidentially to DSI

Do you have an integrity-related question or want to report a possible violation of the DSI Code of Conduct? You can confidentially submit a report to DSI regarding integrity matters. This not only helps to address misconduct but also contributes to a stronger and more ethical financial sector. Reporting can also have a preventive effect.

Report Integrity Issues

Happy holidays and a healthy 2025

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2024 was a year where, together with our partners, we took concrete steps towards an ethical and professional financial sector with skilled professionals. As we look forward to new opportunities in 2025, we wish you and your colleagues happy holidays and a successful start to the new year.

𝗗𝗦𝗜 in 2024: From a new register to our 25th anniversary

2024 was a year full of milestones. We reflect on a period where we further strengthened our mission—an ethical and professional financial sector. Through collaborations with various organizations, we demonstrated that integrity and expertise are the foundation of a strong and trustworthy industry.

We thank all partners and stakeholders who contributed their efforts and cooperation to the success of our activities this year. Watch our film, read the highlights below, and discover what made 2024 special for us:

Certification and Expertise

Social Impact

Strategic Collaborations

Anniversary Activities

  • Anniversary event: 25 years of DSI, with forward-looking insights on sustainability and digitalization
  • Unveiling of AI art as part of our anniversary celebrations
  • Launch of an interactive timeline showcasing 25 years of DSI

Stay up to date on all of DSI’s activities in 2025 through our website, and sign up for our newsletter.

Happy holidays and a healthy 2025

AFM and DSI extend competency agreement

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The AFM and DSI have extended their agreement on professional competency. This agreement, in place since 2018, focuses on employees who provide investment advice or information. The extension is tacit and valid for two years, with no changes to the content.

Floris Mreijen - Director DSI
Floris Mreijen – Director DSI

“The extension of this agreement highlights the importance of professional competency in the investment sector,” says Floris Mreijen, Managing Director of Stichting DSI. “It reinforces our shared commitment to ensuring quality service in the sector. By joining DSI, organizations can rely on us to take care of compliance requirements.”

DSI-Certified professionals are demonstrably competent

The agreement aligns with MiFID II requirements and guidelines from the European regulator ESMA. These standards stipulate that relevant persons—employees who inform or advise on investments—must be demonstrably and continuously competent. The AFM views competent personnel as essential for careful customer treatment and high-quality services in the investment sector.

“We are very pleased with the continuation of this agreement,” Mreijen continues. “DSI certifications are an industry initiative aimed at building trust. The AFM’s recognition confirms the quality and added value of DSI registration.”

Always up-to-date with ‘Continuing Professional Education’

Under the agreement, the AFM and DSI have stipulated that only individuals meeting ESMA guidelines are eligible for inclusion in the DSI ESMA registers. After registration, professionals are required to maintain their knowledge. DSI supports this through the ‘Continuing Professional Education’ program, based on annually updated learning objectives. Training providers develop their programs based on these objectives, ensuring that certified professionals continuously meet the required standards.

The AFM acknowledges that professionals listed in the DSI ESMA registers meet competency requirements. Currently, approximately 4,100 professionals are certified in one of DSI’s seven ESMA registers.

Broad responsibility for organizations

For financial institutions, DSI registration demonstrates that their employees are competent. However, ESMA guidelines also impose broader organizational requirements, such as implementing internal policies and procedures and ensuring employees adhere to them.

DSI registration is not mandatory. Organizations opting not to register with DSI can demonstrate their employees’ competency directly to the AFM. However, the DSI-AFM agreement simplifies compliance with ESMA guidelines for businesses in the sector. Most organizations subject to ESMA guidelines are affiliated with DSI.

Additional Information