Appeals Committee ruling | DSI-2015

Fine and reprimand for unfair market conduct

Ruling DSI Appeals Committee KCHB-2015-1 dated August 3, 2016 (appeal DSI 2015-01)

On August 3, 2016, the DSI Appeals Committee issued a ruling on an appeal against the DSI Disciplinary Committee’s decision of September 3, 2015. The case concerned a former Senior Money Markets Trader who as a submitter for the Euribor rate for many years included requests from traders in her submissions, both from colleagues inside and outside her own organization.

Appeals Board ruling

The Appeals Committee ruled that the defendant’s actions seriously violated the rules of integrity contained in the Code of Conduct. The fact that there were no clear procedures or segregation of duties within the organization does not alter this. Nor does the fact that managers were aware of the course of events relieve the defendant of her own responsibility as a DSI registrant. In imposing the sanction, the Committee took into account the fact that managers were subject to a lighter measure, but considered a reprimand and a fine of €1,500 appropriate.

Articles DSI Code of Conduct applicable: 7.1.1, 7.1.2, 7.1.4, 7.1.5, 7.3.1 and 7.3.2

The Appeals Committee upheld the Disciplinary Committee’s decision: reprimand and a fine of €1,500. No order for costs was issued.

Linkage to DSI Core Principles.

• Core principle 1: Take responsibility:
  As an experienced professional, the defendant had a personal responsibility to act with integrity, even when the organizational culture or leadership directed otherwise.
• Core principle 10: Act honestly:
  Knowingly influencing market indicators such as Euribor violates honesty and damages trust in the financial sector.