DSI Appeal Committee Ruling Posted on May 12, 2025 at 9:40 pm.Written by Roeland Jongejan 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.
New at DSI: 10 core principles for professional integrity Posted on April 9, 2025 at 3:46 pm.Written by Roeland Jongejan 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: Take responsibility – For your own behavior and that of your surroundings. Focus on the client’s interests – Always act in the best interest of your client. Act with care – Show respect and expertise in your work. Show leadership – Promote adherence to the Code of Conduct by others. Follow the rules – Comply with the rules that apply to your profession. Ensure confidentiality – Protect confidential information. Be clear about interests – Prevent conflicts of interest. Communicate openly – Be transparent and avoid misunderstandings. Demonstrate expertise – Provide careful and professional advice to your client. 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.” Posted on March 3, 2025 at 1:35 pm.Written by Roeland Jongejan 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 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.
Challenges for Investment Professionals regarding greenwashing Posted on December 12, 2023 at 1:53 pm.Written by Roeland Jongejan DSI and EY are joining forces in 2023 for roundtable meetings on greenwashing in the financial sector. We aim to facilitate a constructive dialogue among professionals in the investment industry, discussing recent developments and their impact on investment practices. Previous meetings In previous sessions, held in June and September, the focus was on legal, compliance, and marketing aspects of greenwashing. Participants extensively discussed the definition of greenwashing and how organizations interpret this concept. They also reflected on the Progress Report of the European Supervisory Authorities dated June 1st. Read more about these meetings here. Challenges for Investment Professionals During our third meeting on November 22nd, investment professionals collectively discussed challenges related to ESG investing and greenwashing. The growing demand for transparency regarding companies’ sustainable results (and the regulations surrounding them) poses challenges for investment professionals. One of these challenges is the sometimes limited availability of the right data. On the other hand, it was also noted that more data might not necessarily be the solution to the problem of greenwashing. Training During the meeting, investment professionals emphasized the importance of effective communication. It’s crucial to be transparent about the dilemmas surrounding ESG investing. An investment that was previously classified as sustainable may no longer be so later, partly due to regulatory changes. Investment professionals need a basic level of expertise in the ESG field. DSI can play a role in setting standards for competence and integrity. Awareness and future whitepaper It’s essential for organizations to create greater awareness of greenwashing across various sectors. The findings from the three sessions will be compiled into an informative whitepaper, to be shared with the industry in the first quarter of 2024. Contact information For more information about these meetings, you can contact Floris Mreijen, the director at DSI, and/or Mark van der Lecq, the lead legal at DSI.
DSI and EY are organizing a roundtable discussion on Greenwashing Posted on August 25, 2023 at 9:11 am.Written by Roeland Jongejan 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 Posted on March 22, 2023 at 11:09 am.Written by Roeland Jongejan 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.