DSI and EY are hosting a roundtable on greenwashing | Part II

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Challenges in Marketing and Communication

In 2023, DSI and EY are joining forces to organize a series of exclusive roundtable meetings focused on the timely topic of greenwashing and how the financial sector is addressing it. Our goal is to facilitate a constructive dialogue among policymakers from various sectors, discussing recent developments and their impact on investment practices.

Defining greenwashing: compliance and legal aspects

Our first meeting, held in June, focused on the compliance and legal aspects of greenwashing. Participants in this session extensively discussed the current definition of greenwashing and how different organizations interpret this concept. A key talking point was an article published by ESMA on June 1st, exploring the definition of greenwashing through various articles.

Marketing and communication challenges

In our second meeting on September 13th, a new group of specialists discussed the marketing and communication challenges associated with greenwashing. The session began with an introduction and the establishment of objectives. We then engaged in open discussions on various topics. We started by critically examining the current definition of greenwashing and reflecting on its interpretation by participating organizations.

Next, we focused on how an excessive emphasis on commercial incentives can lead to greenwashing. We explored why greenwashing exists in the first place and how organizations and professionals can become involved in this phenomenon. We also discussed the challenges this presents for marketing professionals in carrying out their work.

Moral and ethical considerations in the financial sector

Moral and ethical considerations related to greenwashing were extensively discussed. We examined the differences in ethical perspectives on ESG between investors and institutions offering investment products. We pondered why there is a difference in understanding and whether the financial sector itself should establish concrete frameworks to provide clarity and maintain trust.

Effective communication of ESG performance

Another important point of discussion was how to effectively communicate a company’s ESG performance. We had extensive discussions on how this can be done transparently and accurately. Participants shared numerous practical examples where ESG performance was honestly and clearly communicated to investors.

The final part of the meeting focused on creating awareness within organizations about greenwashing. We discussed how to ensure that this topic is on the agenda at all levels of an organization. Attendees shared valuable best practices.

Upcoming session: greenwashing from an investment perspective

It’s important to note that there will be one more session on Greenwashing in October, this time from an investment perspective, with investment specialists. The findings and insights from these three meetings will be compiled into an informative whitepaper to be shared on our website.

Contact Information

For more information about these inspiring meetings, please contact Floris Mreijen, the director, and/or Mark van der Lecq, the lead legal at DSI.

Renewed and modernized integrity e-learning

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Together with the Dutch Compliance Institute (NCI), DSI has completely revamped the ‘Integrity’ e-learning. This modernized e-learning is designed to raise awareness among financial professionals about the importance of acting with integrity in their daily practice. It is mandatory for anyone seeking certification within one of the DSI registers. You can enroll in the e-learning starting today through the Dutch Compliance Institute website.

Renewed and modernized integrity e-learning ready for use

The e-learning has undergone a thorough makeover. Not only has the content and structure been revised, but all learning objectives have also been meticulously reviewed by NCI in collaboration with members of the DSI Integrity Advisory Committee. During the development, committee members also shared their insights. The result? A completely revised and modernized ‘DSI-Integrity’ e-learning, available for use starting today.

Sign up here for the Integrity E-learning

Efficient E-Learning: Shorter Duration and Focus on Relevance

In addition to changes in structure, we have also considered the time factor for participants. We have critically evaluated the relevance of topics and the length of texts, resulting in a shorter duration for completing the e-learning.

Important to note: the new e-learning is applicable to all professionals, regardless of their role or responsibilities. Integrity is crucial for every professional, and this is highlighted through examples from various work environments. Upon completing the e-learning, there will be an assessment that needs to be passed with a satisfactory grade.

Workshop as an Additional Requirement for Certain Professionals

For some professionals in DSI’s ESMA and Specialists Registers, an additional requirement applies: in addition to the e-learning, they must also successfully complete the DSI Integrity Workshop. This workshop is conducted by the Dutch Compliance Institute in collaboration with Nyenrode Business University. It primarily focuses on applying integrity and critical judgment in practice.

How can I enroll in the e-learning and/or the workshop?

If you wish to enroll in the e-learning and/or the workshop, you can do so through the Dutch Compliance Institute website: www.compliance-instituut.nl. For more information about the Integrity E-Learning, you can also contact the Dutch Compliance Institute at 088-9988100 or DSI at 020-6201274.

Outcomes DSI consultation board meeting

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We recently held our first DSI Consultation Meeting, and we’re eager to share the valuable insights we gained. During this meeting, discussions revolved around current training programs, certifications, and concrete suggestions to improve DSI’s visibility. Concrete action points were established to further strengthen DSI and increase engagement.

Training & Examinations:

Engaging discussions centered on the structure of training and examinations, which vary between providers, raising questions about uniformity. It was clarified that while providers have flexibility in their approach, they must align with the learning objectives. DSI has committed to ongoing dialogue with providers and feedback discussions.

Certification:

We explored opportunities to expand and deepen registers, touching on themes such as sustainability, digitization, and financial crime. Some expressed a desire for more tailored training and perhaps a register for specialists in specific areas. DSI will incorporate this feedback into the ongoing strategy development. We have already taken the first step in this direction by developing the DSI Financial Crime Professional register.

Importance of Visibility:

Many valuable tips were shared, emphasizing the importance of DSI’s visibility. We aim to share more information, both online and offline, and seek input from certified professionals on current topics. DSI is evolving into a platform open to all stakeholders. We will utilize LinkedIn to actively engage professionals.

Action Points for DSI:

– Enhance visibility (e.g., through LinkedIn).
– Develop an information package for certified professionals.
– Research improvements in training programs.
– Provide clear explanations of ESMA registers on the website.

We thank the participants of the DSI Consultation Group, consisting of 8 certified professionals, for their active contributions and look forward to future developments. If you are interested in joining the consultation group and shaping the future of DSI, there is still room for 2 more members. Sign up here!

What does the DSI Consultation Group entail?

The consultation group consists of a fixed group of up to 10 certified professionals from various DSI registers. The group meets twice a year for a meeting at Beursplein in Amsterdam. During these meetings, various developments and services of DSI are discussed, focusing on how we can bring DSI closer to professionals and align our strategy accordingly.

Complete your Continuing Education for the end of 2023

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Keeping your knowledge up to date: follow the DSI Continuing Professional Education (PE) Program 2023! Every year, we update the PE program to align with the latest developments in the sector and changes in regulations. Successfully completing the PE program is essential to maintain your full DSI certification.

With this message, we would like to draw your attention to the timely completion of the PE program that matches your DSI registration. Why? Because it keeps your knowledge current, and you can immediately apply the insights gained in practice.

Furthermore, completing the PE program is a crucial part of the ESMA requirement. Failing to complete the PE program on time can have direct consequences for your daily work as a professional.

Have you successfully completed PE 2023?

Depending on your training provider, you may have already successfully completed PE 2023. If that’s the case, congratulations! You don’t need to take any further action at this time. In January 2024, we will receive a list of successful candidates from all training providers. At that time, we will process your results and update them in the Public Register.

If you have multiple DSI registrations, you need to complete the specific PE program for each registration. Please note that the PE program is not mandatory for certified individuals who are only registered in the Integrity Register.

Verify if your chosen PE program matches your registration.

It’s essential to verify if the PE program you have chosen aligns with your DSI registration. If you have any doubts, please feel free to contact us. This will help avoid unnecessary confusion. Remember that if, for example, you are registered in the Advising Standard Retail Investment Register, you should follow the PE program for Advising Standard Retail Investment, not the program for Informing Retail Investment.

Registered before January 1, 2023, means mandatory completion of PE 2023.

If you registered before January 1, 2023, you are required to successfully complete PE 2023. Candidates who applied for (candidate) certification in 2023 will start with PE 2024 from January 1, 2024. Consult the information about PE 2023 for more details.

Make sure to complete PE 2023 before the end of the year.

While you still have some time, we strongly recommend starting the program as soon as possible if you haven’t already. On our website, you’ll find a list of training providers offering the PE 2023 program. Don’t forget to consult with your employer first to see if specific arrangements have been made with a particular training provider, as this can impact your choice. The deadline for completing PE 2023 is April 1, 2024.

Consequences of not completing PE 2023 on time.

Annually, you must successfully complete the Permanent Educatie program if you hold a DSI certification. Failing to do so on time may have direct consequences for both your work and your registration in the DSI Public Register. If you don’t pass the PE, your registration will be changed to ‘Candidate Certified,’ which means you no longer meet ESMA guidelines. This could also result in your employer needing to supervise your work if you haven’t completed PE 2023.

More information and contact

For more information and to get in touch with us regarding the Continuing Professional Education program, please visit www.dsi.nl/en/pe2023 or submit a question via our contact page.

Termination of passive certified status

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From January 1, 2024, DSI will discontinue offering the passive registered status. DSI is providing passive registrants the opportunity to convert their registration to a (candidate) certification before this date. All passive registrants have been informed about this option through personal emails.

Why is DSI discontinuing the passive registration status?

With a DSI Certification, professionals in the investment sector demonstrate their competence and stay updated on the latest developments in integrity, knowledge, and skills. Passive registration was introduced in the past to temporarily exempt certified individuals from the obligations associated with certification. Passive certified individuals do not meet the requirements of a DSI Certification. As this no longer aligns with our current DSI registry policy, we are discontinuing this status and offering an alternative.

How to convert a passive registration?

To be certified by DSI, you need to be employed by a participant affiliated with DSI. If you currently work for an organization that is not a DSI participant and you wish to convert your passive registration, we advise discussing the option of becoming a DSI participant with your employer. After your employer’s acceptance as a participant, you will go through a process to convert your passive registration to active registration. Click this link for more information on enrolling your employer as a participant.

Reactivate your certification

If you currently work for an employer affiliated with DSI but are passively certified, you can directly reactivate your certification through your MyDSI account. In MyDSI, you can request a change from passive registration. Click the “I want to change my passive registration” button in MyDSI for more information.

Click here for (re)activation of a passive DSI registration

Competency requirements for DSI registries

When (re)activating your certification, you must fulfill all competency components of the respective registry. Click here to gain immediate insight into the associated competency requirements per registry. If you haven’t met all competency requirements yet, no problem – you will be candidate-certified until all components are fulfilled.

Respond by January 1, 2024

If we do not receive a response from passively certified individuals by January 1, 2024, the registration with DSI will be automatically terminated. We extend our gratitude to all certified individuals for their involvement with DSI and invite everyone to subscribe to the DSI newsletter to stay informed about future developments.

More information

If you need more information about your DSI registration or if you are passively certified and have not received a letter from us, please contact us through our contact form or call our Customer Care Officers at 020-6201274. They are here to assist you.

DSI and EY are organizing a roundtable discussion on Greenwashing

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DSI and EY are joining forces in 2023 to organize a series of exclusive roundtable meetings, focusing on the current topic of greenwashing and how the financial sector is addressing it. Our goal is to facilitate a constructive dialogue among policymakers from various sectors, discussing recent developments and analyzing their impact on investment practices. The discussion will revolve around the moral and ethical considerations related to greenwashing. The valuable insights derived from these meetings will be compiled and presented in an informative white paper by the end of the year.

Greenwashing from different perspectives

The first meeting took place on June 7th at Beursplein in Amsterdam, with a focus on compliance and legal aspects. This session brought together professionals from risk, legal, and compliance domains of various DSI participants.

After an introduction and setting the meeting’s objectives, open discussions covered various topics. Firstly, the current definition of greenwashing was critically examined. What does this term precisely entail, and how do the present organizations interpret this theme? We reflected on an ESMA article published on June 1st that explores the definition of greenwashing based on various articles.

Current regulation surrounding greenwashing

Subsequently, our attention turned to the current regulations. Greenwashing is addressed through several European sustainable finance regulations. Together, we discussed how organizations navigate this complex set of rules. How do they implement these guidelines, and which regulations have the most significant impact on their operations?

Moral and ethical considerations regarding greenwashing were also extensively discussed. We explored the differences in ethical standpoints on ESG between investors and institutions offering investment products. Why does such a disparity in understanding exist, and should the financial sector itself establish concrete frameworks to provide clarity and maintain trust?

Creating awareness about greenwashing within your organization

The final part of the meeting focused on creating awareness about greenwashing within organizations. How can we ensure that this topic is on the agenda at every level of the organization? Attendees shared valuable best practices, which we will elaborate on in the white paper scheduled for publication at the end of the year.

After the summer, DSI and EY will host two more sessions on Greenwashing, but this time from a different perspective, involving marketing and communication specialists, as well as investment experts. The findings from these three gatherings will be consolidated into an informative white paper, to be shared on our website.

For more information about these inspiring meetings, feel free to reach out to Floris Mreijen (Director) and/or Mark van der Lecq (Lead Legal) by sending an email to certificering@dsi.nl.

Outcomes of DSI Disciplinary Cases

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Over the past period, DSI has conducted and resolved various Disciplinary Investigations. One of the outcomes involved a reprimand issued by the DSI Disciplinary Committee to a Senior Relationship Manager Private Banking employed at a bank. We have summarized the results of all investigations in a brief overview. This summary provides insights into the various ways DSI handles disciplinary matters.

Revocation of Certification by DSI

On December 14, 2022, DSI revoked the certification of a partner from an investment firm under article 6.2 of the General Regulations. This article allows for certification revocation if the certified individual no longer complies with DSI’s regulations or breaches any provision therein. DSI believed that revocation was appropriate in this case due to the certified individual receiving a fine from the AFM (Authority for the Financial Markets). Additionally, the certified individual had not fulfilled the obligation to complete the Permanent Professional Competence program.

The certified individual had the option to appeal the revocation decision by DSI through the DSI Disputes Committee. However, the certified individual chose not to appeal, making the revocation final.

Transaction

Under the General Regulations, DSI is empowered to impose disciplinary measures through a transaction, which may entail a fine or an educational measure.

On January 3, 2023, DSI presented a transaction proposal to an investment advisor employed at a bank. DSI’s investigation had revealed that the certified individual had accessed customers’ bank accounts without a valid business reason. When considering the transaction proposal, DSI took into account measures already imposed by the bank and the certified individual’s demonstrated insight into their erroneous actions, which they also self-reported to DSI.

The transaction involved a corrective measure in the form of a mandatory integrity and critical judgment workshop. The certified individual accepted the transaction and has successfully completed the workshop, along with the accompanying examination.

Dismissal

On January 12, 2023, DSI decided to conclude an investigation against a DSI certified securities trader. DSI had initiated the investigation due to media reports about a criminal inquiry into insider trading. Upon receiving confirmation that the public prosecutor’s office had dropped the case against the trader, DSI closed the file.

Disciplinary Committee ruling

On February 21, 2023, the DSI Disciplinary Committee issued a ruling in a case involving a Senior Relationship Manager Private Banking employed at a bank. In the complaint, DSI highlighted the certified individual’s careless handling of confidential information and their actions giving rise to the appearance of a conflict of interest. The Disciplinary Committee found DSI’s complaint justified and imposed a reprimand on the certified individual.

AFM and DSI extend covenant on professional competence

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AFM and DSI extend covenant on professional competence. The Netherlands Authority for the Financial Markets (AFM) and Stichting DSI (DSI) have extended the covenant they have had since 2018 with regard to the professional competence of employees who provide information or advice on investments. “Extending this covenant strengthens confidence in the investment sector,” said Tanja Nagel, chairman of Stichting DSI.

This is a tacit extension of two years. This means that AFM and DSI will continue the agreement without amendments.

DSI certified persons are demonstrably competent
The covenant follows from professional competence requirements included in MiFID II. It states that anyone who informs or advises on investments (relevant persons) must be demonstrably ‘competent’. The requirements for this are described in guidelines from the European regulator ESMA. The AFM considers skilled personnel to be an important precondition for good investment services and careful treatment of clients.

“We are very pleased with the continuation of the covenant with the AFM,” says Tanja Nagel. “DSI certifications are an initiative of the financial sector itself to strengthen confidence in the investment sector. Recognition of this certification by the regulator offers additional confirmation of the quality and added value of a registration in one of the DSI registers”.

DSI certificates comply with ESMA guidelines
The AFM and DSI have agreed in the covenant that DSI only admits relevant persons in its registers who comply with the ESMA guidelines. Once in the registers, the obligation to keep knowledge up-to-date applies. DSI has introduced the “Continuing Professional Education program (Permanent Vakbekwaam Programma)” for this purpose. Trainers offer this program to certified persons on the basis of learning objectives updated annually by DSI.

In accordance with the covenant, the AFM recognizes that everyone included in a relevant DSI register is professionally competent. Currently, around 5,000 professionals from the investment sector are certified in one of the seven ESMA registers at DSI.

ESMA guidelines apply to the entire investment firm
A DSI registration for the relevant persons does not mean that the company fully complies with the ESMA guidelines. The standards in the guidelines are broader. For example, organizational requirements for the company have been included. Employees must also be aware of (and understand and apply) the company’s internal rules of conduct and procedures. Because the elaboration of this is specific to each company, it is not part of the certification at DSI.

The extension of the covenant will make it easier for investment firms to comply with the ESMA guidelines. A DSI registration is not mandatory. Companies that do not want this can also demonstrate to the AFM for each employee that they are professionally competent and how this is organized within the organization.

Additional information:

Link to AFM-DSI covenant – click here
Link to Include ESMA Guidelines – click here
Link to MiFID II – click here
Link to AFM press release – click here

Amsterdam stock exchange opening by DSI and Validata

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Collaboration agreement DSI Foundation and Validata

The DSI Foundation and Validata together stand for honest and reliable professionals in the investment sector. On the occasion of the collaboration in the field of the screening of DSI certified professionals, Floris Mreijen, General Manager of DSI since the 1st of April, opened the Amsterdam stock exchange together with Validata this morning the 5th of July.

The DSI Foundation was established on 14 April 1999 as a self-regulatory institute for the investment sector. DSI Foundation’s core task is to work with the sector to ensure that society has greater trust in the financial sector. DSI does that by:

  • Formulating norms for knowledge, skills en integrity;
  • Accrediting examinations and educational programmes;
  • Certifying professionals who meet the stated DSI norms, and listing these professionals in the DSI Public Register;
  • Holding Certified Professionals accountable for violations of the DSI Code of Conduct through DSI Ethics Enforcement.

Employment screening of DSI certified persons

An employment screening is part of a certification application at DSI. With this we provide an extensive check of professionals in the field of work experience and training at the front of a DSI registration. To carry out this employment screening, the board of DSI has opted for the services of Validata Group. DSI currently carries out this screening itself. The collaboration is expected to start after the summer. DSI participants will receive further notice from which date this will be.

Why Validata Group

Validata Group is a professional screening organisation with many years of experience in the field of employment screening Validata places a high value on quality certifications (incl. ISO), IT security and privacy. Validata has a modern IT platform that supports or facilitates all of the most common connections with (potential) customers’ HR software applications. Plus, Validata already serves many major employers in the financial sector. That gives us every confidence that Validata is the high-quality professional and flexible partner with whom DSI and our clients can do business, both today and in the future.

Questions about the competence of investment professionals?

If you have any questions about DSI Certification, please visit the FAQ page with answers to the most frequently asked questions. If you cannot find your question in the FAQ page, or you need personal advice about requesting a specific certification, please feel free to contact us by mail at: certificering@dsi.nl or call us at 020-6201274. We would be happy to help you!

Floris Mreijen new Director of DSI Foundation

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The Board of the DSI Foundation is pleased to welcome Floris Mreijen as the new Director of the DSI Foundation as of 1 April 2022. He will take over from Joost Melis, who served in the position on an adjunct basis.

Floris Mreijen has served in a variety of leadership positions at the Nederlandse Vereniging van Banken (Dutch Banking Association, NVB) for the past several years, where he acquired a wealth of experience and knowledge in managing and developing the vital branch association for the financial sector. Throughout his career, Floris Mreijen has advocated for issues related to integrity, sustainability, and the consumer’s trust in financial institutions. Floris’ most recent post was as Adjunct Director of the NVB.

DSI Board President Tanja Nagel is pleased with Floris Mreijen’s arrival: “The needs of consumers, professionals and financial institutions is subject to many changes, and DSI must continue to adapt to these changes. Moreover, fair and honest behaviour and professional expertise are essential issues in our sector and in society at large. We appreciate that Floris Mreijen will now devote his knowledge, experience and network for the benefit of our foundation. Together, we will continue to build the DSI Foundation and strengthen the public’s trust in the investment sector.”

DSI Foundation wishes to thank Joost Melis for his contributions to strengthening trust in the investment sector as Adjunct Director of DSI.