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.

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.”

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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.