Ruling Disciplinary Committee | DSI 2018-03

Fine for careless handling of confidential information – I

DSI Disciplinary Committee ruling 2018-03 dated June 19, 2019

On June 19, 2019, the DSI Disciplinary Committee ruled in a case against a former Senior Asset Manager and board member of a financial institution. The complaint concerned the careless handling of confidential information about the introduction of the Ultimate Forward Rate (UFR) by De Nederlandsche Bank (DNB), which came to the company and the defendant via the Association of Insurers.

Disciplinary Committee ruling

The Disciplinary Committee found that the Respondent used confidential information to conduct transactions that served the commercial interest of the company. The Respondent, as a board member of the Alliance, should not have used this information for internal decision-making and should have engaged compliance. Also, the confidential information was shared with colleagues without sufficient due diligence. The committee took into account the Respondent’s personal circumstances during the period in question, but found the complaint partially justified.

Articles DSI Code of Conduct applicable: 7.1.2 and 7.1.3

The Disciplinary Committee imposed a fine of €2,500 on the Respondent, taking into account that the acts had now occurred seven years ago. No order for costs of proceedings was imposed.

Linkage to DSI Core Principles.

• Core Principle 1: Take responsibility:
  Respondent had an exemplary role as a board member and was required to take responsibility for handling confidential information with integrity and complying with the Code of Conduct.
• Core Principle 6: Ensure confidentiality:
  Sharing and using strictly confidential information to conduct transactions violates the standard of handling confidential data carefully within the financial industry.