Ruling Disciplinary Committee | DSI 2004-01

DSI Disciplinary Committee ruling dated June 10, 2004.

The DSI Disciplinary Committee ruled in a case against a senior Securities Trader who, as a manager, was responsible for a department where irregularities in the calculation of commissions and margins occurred over an extended period of time, due to the swapping of the roles of agent and principal. Although this practice existed prior to his appointment, the committee ruled that a manager could be expected to actively promote compliance and discuss irregularities. The committee found no evidence that the defendant had not sufficiently cooperated with the internal investigation, but it did find that as a manager he had not adequately fulfilled his responsibilities.

Disciplinary Committee ruling

The Disciplinary Committee deemed the complaint partially founded and imposed the measure of a reprimand on the defendant, in part because he had actually been suspended for a year during the investigation.

Articles DSI Code of Conduct applicable: 7.1.1, 7.1.2, 7.1.3, 7.1.4, 7.1.5, 7.2.1, 7.2.2

Linkage to DSI Core Principles:

• Core principle 4: Show leadership.
  As a manager, Respondent had an exemplary role and responsibility to actively promote integrity and compliance.
• Core principle 1: Take responsibility.
  Even in an existing culture, individual responsibility remains to identify and address wrongdoing.
• Core principle 5: Comply with rules
  Correctly applying rules around commission and margin calculation is essential for trust in the industry.
• Core principle 3: Act carefully
  Carefulness in monitoring processes and identifying irregularities is a core duty of every manager.