Ruling Disciplinary Committee | DSI 2006-03

DSI Disciplinary Committee ruling dated February 1, 2006.

The DSI Disciplinary Committee ruled in a case against a senior asset manager and Investment Analyst, who was accused of acting with inside information during transactions in holding companies, both privately and for clients. The court had convicted the defendant of insider trading, but the defendant argued that he was unaware of confidential discussions between his employer and the Treasury Department and that he had instead made internal inquiries about the permissibility of the transactions. The committee ruled that there was no evidence that the defendant had price-sensitive information or initiated deviant purchasing policies. The documents also showed that the purchasing policy had not changed and that the defendant had acted carefully by making internal inquiries.

Disciplinary Committee ruling

The Disciplinary Committee deemed DSI’s complaint unfounded and dismissed it.

Articles DSI Code of Conduct applicable: 7.1.1, 7.1.2

Linkage to DSI Core Principles:

• Core principle 6: Ensure confidentiality.
  There was no evidence that confidential information was misused or shared.
• Core principle 1: Take responsibility.
  The defendant has taken responsibility by making internal inquiries when in doubt about the permissibility of transactions.
• Core principle 3: Act carefully
  Acting with care and questioning internal rules are essential for trust in the industry.