CISI Code of Conduct

Membership of the CISI requires members to meet standards set out within the Institute's Principles. These Principles impose an obligation on members to act at all times not only in compliance with the rules, but also to support the underlying values of the Institute.

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Code of Conduct

Professionals within financial services owe important duties to their clients, the market, the profession and society. Where these duties are set out in law or regulation the professional should comply with the requirements in both letter and spirit.

Members of the Chartered Institute for Securities & Investment (CISI) are also required to meet the standards set out within the principles of the CISI’s Code of Conduct, which impose an obligation on members to act at all times not only in compliance with the rules, but also to support the underlying values of the Institute.

Each Principle specifies the duties owed by members to one or more stakeholders who may be impacted by their actions.

There may be situations where professionals are faced with making a decision where the correct course of action is not immediately obvious. In addition to referring to the Code, consideration of the following simple checklist will help to decide the best course of action; is the course of action you are considering honest, open, transparent, and fair?

Clear

Have I told no lies or ‘half-truths’ to any party involved in reaching my decision?

Impartial

Is everyone affected by my action or decision aware of the consequences?

Straightforward

Have I made sure that my action or decision will not result in any party being unknowingly disadvantaged or unduly advantaged?

Informed

Have I considered the interests of my potential stakeholders and not been misleading when making my decision?

CISI Code of Conduct - Principles

Principle - Personal Accountability
Stakeholder(s): Self, Clients, Regulators, Colleagues, Market Participants, Firm, Profession, Society
To strive to uphold the highest levels of...
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Principle - Client Focus
Stakeholder(s): Clients
To put the interests of clients and customers first...
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Principle - Conflict of Interest
Stakeholder(s): Clients, Market Participants, Regulators
Being alert to and actively manage fairly...
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Principle - Respect for Market Participants
Stakeholder(s): Clients, Market Participants
To treat all counterparties and business partners with respect...
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Principle - Professional Development
Stakeholder(s): Profession, Clients, Colleagues
To strive continually for professional excellence...
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Principle - Aware of Capabilities
Stakeholder(s): Clients, Profession, Market Participants
To decline to act on any matter about which...
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Principle - Respect Others and the Environment
Stakeholder(s): Society, Colleagues, Clients, Regulators, Market Participants, Profession, Professional Body
To treat everyone fairly and with respect...
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Principle - Speak Up & Listen Up
Stakeholder(s): Society, Colleagues
To be active in speaking up and...
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Disciplinary Process

One of the Institute’s foremost objectives is to promote the highest standards of trust, integrity and ethics amongst its members and throughout the securities, investment, wealth and financial planning professions generally.

To ensure these high standards are upheld, it is necessary to also ensure that members comply with the Institute’s Royal Charter & Bye Laws and Membership Regulations (including the CISI Code of Conduct) through the Institute’s disciplinary process.


The Institute’s disciplinary process is overseen and directed by the Disciplinary Committee.

The Disciplinary Committee delegates its decision-making authority to the Disciplinary Review Panel (DRP) who review all cases, in the first stage. The DRP consider all information provided and written representation from the member, before making their decision on whether there appears to be a case to answer. In doing so the DRP may:

  • refer the matter to the Disciplinary Panel; or
  • if the offence is not an Administrative Offence and not considered sufficiently material for referral to the Disciplinary Panel, they may send an appropriate strongly worded warning letter reminding the member of the Institute’s expected levels of behaviour as well as recommending additional CPD which could include the retaking of the IntegrityMatters test, or
  • should there be no case to answer, close the case.
  Guidance for members on the disciplinary process

Summary of the CISI Disciplinary Process

Step 1
Misconduct allegation received by the CISI Professional Standards team. The team will review the information to see if it is appropriate for the CISI to investigate, and proceed accordingly.
Step 2
Should there be grounds for an investigation, the misconduct allegation will be reviewed by the Disciplinary Review Panel. The Disciplinary Review Panel decide whether or not, there is a case to answer.
Step 2: Scenario One
The Disciplinary Review Panel could conclude that there is "no case to answer", in which case the member will be notified, and no further action will be taken.
Step 2: Scenario Two
Scenario Two: The Disciplinary Review Panel could conclude that there is a "case to answer" and the member will be notified.
Step 3
Should there be a "case to answer" the member will be informed of the formal allegations, and given the opportunity to provide further information, e.g. written evidence/statement.
Step 3: Scenario One
Scenario One: After further investigation, the Disciplinary Review Panel could conclude there is "no case to answer". The member will be notified, and no further action will be taken.
Step 3: Scenario Two
The Disciplinary Review Panel could conclude there is a case to answer, the member will be notified that their case will be referred to the Disciplinary Panel.
Step 4
Should there be a "case to answer", a Disciplinary Hearing will be scheduled which the member can attend with a guest of their choosing. A report to the Disciplinary Panel will be shared with the member and panel, which will provide detailed information on the case, any written submissions and evidence prior to the hearing date.
Step 5
Once the Disciplinary Panel has reached their final decision, there will be either (a) sanctions imposed (b) no further action to take. Should the member wish to, they can request to appeal the decision.
Step 6
In summary, possible sanctions, should they be imposed include: additional hours of CPD; completion of IntegrityMatters test; denial of CISI facilities; reprimand; severe reprimand; suspension; reduction in member status and expulsion.
Step 6: Scenario One
Case has been concluded, and the member has not made a request to appeal.
Step 6: Scenario Two
Scenario Two: The member has made a request to appeal, which has been approved, and the case is heard by the Appeals Panel.
Step 7
Appeals Panel reach the final decision and the findings are either upheld amended or overturned.

On an annual basis, members are required to declare any breach(es) of the CISI Membership Regulations or Code of Conduct, in a timely manner. This may be in relation to:

  • Failure to satisfy a judgement debt
  • A Bankruptcy order or IVA
  • A criminal conviction
  • Disciplinary action/sanction by their employer
  • A disciplinary sanction/fine imposed by a Regulatory Body or other Professional Body

Please note that failure to report a breach could lead to a further disciplinary action being taken against a member for non-disclosure.

How to Self-declare a disciplinary offence:

If not already declared, members are required to make a declaration via their annual renewals for Membership, SPS, CFP™ or Certificate of Professionalism.

Additionally, Members can make a declaration by emailing standards@cisi.org with the following information:

  • the nature of offence/incident
  • chronology of event(s)
  • relevant details and supporting documentation (Disciplinary Hearing invitation/Outcome letter)
  • relevant written representations regarding the matter, which may include any mitigating circumstances you wish to be considered.

A disciplinary offence is a breach of the CISI Membership Regulations – these are the rules that govern the professional behaviour of all CISI members. A full list of disciplinary offences can be found in section 16 of the CISI Membership Regulations.

In summary, the Institute can take disciplinary action against any member who:

  • (a) commits any act likely to bring discredit to himself/herself
  • (b) performed work incompetently
  • (c) failed to satisfy a judgement debt
  • (d) entered into an Individual Voluntary Agreement (IVA) or International equivalent and defaulted on payment
  • (e) breached any of the CISI Regulations
  • (f) failed to pay membership
  • (g) failed to undertake the required amount of CPD
  • (h) failed to comply with an order of the Disciplinary Panel
  • (i) pleaded guilty or been found guilty by a court of a criminal offence
  • (j) received a penalty including a reprimand imposed by a Regulatory Body or other Professional Body

Please note a member shall not be considered guilty of a disciplinary offence by virtue of any act, omission or failure occurring at a time before they became a member of the Institute provided that the member made a full and frank written disclosure of the act, omission or failure in connection with their application for membership.

If a member has been found to be in breach of the CISI Membership Regulations and receives a sanction as listed under 19.2 of the CISI Membership Regulations, they may incur an administrative cost in relation to the proceedings, which will be payable to the CISI.

Members may be awarded all or part of the administrative costs incurred from disciplinary proceedings, which usually are:

  • Disciplinary Hearings – minimum of £500
  • Administrative Sanctions- minimum of £100

Please note, cases that have pro-longed timelines, require legal representation or expert witnesses may lead to higher costs.

Costs allocated must be paid within 31 days of the date of the Disciplinary Panel’s order (or such longer period as the Disciplinary Panel determines). The determination of the allocation of costs, will be reviewed in relation to the member’s financial stability.

The member will be able to make a representation in respect of costs and will also be given a timeline to appeal any decision made by the CISI.

 

Complaints

Do I need to raise a complaint?

Professionals within securities and investment owe important duties to their clients, the market, the profession and society at large. Where these duties are set out in law, or in regulation, the professional must always comply with the requirements in an open and transparent manner. A material breach of the Code of Conduct would be incompatible with continuing membership of the CISI.

How complaints are handled

Allegations brought to the attention of the CISI, in relation to members who may have breached CISI Membership Regulations or the Code of Conduct, will be investigated and members will be given the opportunity to provide representation. Should it be found that a breach of the Membership Regulations/Code of Conduct is apparent, the CISI will initiate Disciplinary procedures.

Please note that a complaint to the Institute is not a substitute for using a firm’s established complaint handling procedure, nor can it cover complainants seeking financial redress.

The CISI has no regulatory jurisdiction or investigatory powers. Complaints relating to the delivery of professional services should be made in the first instance to the provider of those services, in line with such provider’s terms of business. Failure by the firm to provide a satisfactory response or redress to your complaint should then be referred to the Financial Ombudsman Service, or the Financial Conduct Authority (FCA).

What other options are available to me?

Other bodies may be able to support you.

In the UK

Regulators
  • Financial Conduct Authority Website (FCA): How to complain,
  • Prudential Regulation Authority (PRA)
Financial Ombudsman Service (FOS).
  • Financial Ombudsman Service (FOS).
Advice and guidance
  • Citizens Advice Bureau
    Citizens Advice Bureaux are local, independent charities that provide free and confidential advice and information whoever you are and whatever the issue is.
  • The Advisory, Conciliation and Arbitration Service (ACAS)
    Provides free and impartial advice on aspects of workplace relations and employment law.
  • Protect
    Provides confidential advice for individuals in relation to whistleblowing.

In Spain

Financial Compensation or Redress
List of Financial Advisory Firms
Advice, Consulting, Technical Assistance Training
Secretary of State for Employment and Social Economy
Citzen’s Advice

In the UAE

Regulators

In Sri Lanka

Regulators
The CISI can only discipline members breaches of the CISI Membership Regulations, and Code of Conduct. It may be more appropriate for you to refer your complaint to another regulatory body, for example the FCA.

Have you spoken to the individual's employer?

Yes No
It may be possible to address the issue quickly by talking to the person involved, or their employer. This gives them the chance to look into the matter and put it right. Details of how to make a complaint should be available on the firm's website.

Should you still wish to raise a complaint, you can do so here.

Was your complaint handled to your satisfaction?

Yes No
If you are not happy with the response, the individuals employers rejects your complaint or you do not hear from them within 8 weeks, the Financial Ombudsman Service may be able to help you.

Should you still wish to raise a complaint, you can do so here.
Please advise us of the outcome using the complaints form.

How do I raise a formal complaint with the CISI ?

Please complete and submit the complaint form.

Please note the CISI does not investigate anonymous complaints, but as a complainant, you can ask that we keep your identity confidential.

Disciplinary Findings

Disciplinary findings will appear on the CISI website for as long as a sanction remains on a member’s record. The recommended time a sanction should remain on a member’s record is set by the Disciplinary Panel, and is usually 12 months from the date of the hearing.

A Disciplinary Panel may determine that a member is in breach of the regulations, and impose a sanction, but use their discretion not to publish the findings. Reasons why a Disciplinary Panel may determine that publication is inappropriate include (but are not limited to):

  1. That doing so would harm a third party;
  2. The member is considered to be, and has provided information to demonstrate, that they are a vulnerable individual;
  3. That doing so would prejudice an ongoing investigation into the same/similar matter by another organisation.

It is necessary to ensure members comply with the Institute’s Charter, Bye-Laws and Regulations (including the CISI Code of Conduct) through the Institute’s disciplinary process. The application and administration of the Institute’s disciplinary process shall be overseen and directed by the Disciplinary Committee.

CISI Member, ACSI June 2022

The FCA found that this individual had failed to take reasonable steps in ensuring that he complied with relevant regulations in relation to conflicts of interest. The FCA also found that the member had failed to act with due skill, care, and diligence by breaching the Gifts and Entertainment Policy in operation at his firm. Consequently, the member breached Principle 2 and Principle 7 of the FCA’s Statements of Principle and Code of Practice for Approved Persons, and therefore, the FCA imposed a financial penalty of £230,037 on the member.

The CISI found that the member had breached paragraphs 16.1 (a), (b) and (e) and 16.2 (b) of the CISI Membership Regulations and has therefore been sanctioned with a severe reprimand to stay on record for 6 months. During this time, the individual’s membership with the CISI will be suspended. The individual is also required to retake the CISI IntegrityMatters test and an additional three hours of relevant CPD, within the current CPD year.



Alan Northmore, MCSI (Chartered status suspended) May 2022

In 2021, the Guernsey Financial Services Commission conducted an investigation that identified that Mr Alan Northmore had failed to demonstrate that he acted with competence, soundness of judgement and diligence, due to a number of failings related to a Politically Exposed Person (“PEP”) and not ensuring that the Licensee’s procedures and controls were appropriate and effective with regard to the Licensee’s high-risk appetite. As a result, the Guernsey Financial Services Commission imposed a financial penalty of £56,700 on Mr Northmore, under section 39 of the Enforcement Powers Law.

The CISI found that Mr Northmore had breached paragraphs 16.1 (a) and 16.2 (b) of the CISI Membership Regulations and he has therefore been sanctioned with a reprimand to stay on record for 12 months. During this time, Mr Northmore will also have his Chartered status suspended.



Brett Armitage, formerly Chartered MCSI May 2022

The Isle of Man Financial Services Authority conducted a supervisory inspection in respect of Bridgewater (IOM) Limited, that identified contraventions of the Anti-Money Laundering and Countering the Financing of Terrorism Code 2019 (“the Code”) (“the Contraventions”). The Investigation identified a range of issues which caused it to assess the fitness and propriety of the persons undertaking certain controlled functions at Bridgewater (IOM) Limited. As a result, the Authority concluded that the individuals holding such roles are not fit and proper to hold the roles at Bridgewater (IOM) Limited and, in certain instances, in the regulated sector in the Isle of Man and therefore exercised its powers under s.10A of the Act to prohibit those role holders from continuing in those positions. As a result, Mr Armitage is prohibited from working in the financial services industry in or from the Isle of Man for five years.

The CISI found that Mr Armitage had breached paragraphs 16.1 (a) and (e), as well as 16.2 (b) of the CISI Membership Regulations. As such, Mr Armitage has been expelled from CISI membership for 5 years, to run coterminously with his sanction from the Isle of Man Financial Services Authority and has therefore, forfeited his Chartered MCSI designation.



Abiodun Alebiwou, ACSI April 2022

The Securities and Exchange Commission in Nigeria (SEC) identified a series of failings in relation to Mr Alebiowu’s role as a sponsored individual of Amyn Investments Limited (AIL). This included failure to notify the SEC of unprofessional behaviour and breaches of SEC Rules and Regulations at AIL and failing to remit the proceeds of a sale. As a result, the SEC banned Mr Alebiowu from participating in all capital market activities and holding a directorship position in any public company in Nigeria for a period of three months from the 10th of November 2020 to the 10th of February 2021.

The CISI found that, due to his professional activities having been found by a regulator to have been capable of adversely affecting confidence in capital markets, Mr Alebiowu had breached paragraph 16.1 (a) of the CISI Membership Regulations. Furthermore, due to a penalty having been imposed on him by a regulator, he also breached paragraph 16.2 and, because of his delay in notifying the CISI of his investigation and punishment by the SEC, he breached paragraph 16.1 (e), with particular focus on the CISI Code of Conduct in relation to Personal Accountability.

As a result, Mr Alebiowu received a reprimand from the CISI to stay on his membership record for 12 months. In addition, Mr Alebiowu will be required by the CISI to complete both three additional hours of CPD and the CISI IntegrityMatters test within six months.



Gufur Hussain, formerly Chartered MCSI September 2021

The Jersey Financial Services Commission (the “Commission”) determined that Mr Hussain had failed to declare conflicts of interest in dealing with clients, overridden safety measures put in place by the Commission to protect a client who had been deemed a ‘vulnerable person’ and on several occasions failed to disclose certain information requested by or due to the Commission. The Commission concluded that Mr Hussain lacks integrity and therefore banned him from performing any function for, engaging in any employment with, or holding any position in any business licensed to conduct financial services in Jersey without the prior written approval of the Commission.

The CISI found Mr Hussain to have breached Clauses 16.1 (a) (as a result of contravening 16.2) and 16.1 (e) of the CISI Membership Regulations, as well as several CISI Code of Conduct principles.

As a result, Mr Hussain has been permanently expelled from CISI membership and forfeited his Chartered MCSI designation.



Kevin Gilligan, ACSI June 2020

The CISI discovered that Mr Gilligan had been personally sanctioned by the Guernsey Financial Services Commission and prohibited from performing the functions of director, controller, partner or manager of a regulated entity for six years and two months. The Commission’s investigation found that a regulated firm, of which Mr Gilligan was a director, failed to (1) administer certain funds in accordance with the principal documents and information particulars, (2) abide at times with contractual and legal obligations, (3) adequately identify and manage conflicts of interest, (4) obtain adequate client due diligence and enhanced due diligence in relation to its book of business, (5) at times effectively monitor business relationships and transactions, (6) at times, to ensure that proper books and records were kept and that these were readily retrievable and (7) at times, to exercise effective policies procedures and controls for forestalling, preventing and detecting money laundering and terrorist financing. It also found that the directors failed, at times, to adhere to a director’s fiduciary duty to act in the best interest of a company.

Mr Gilligan was found to have breached the disciplinary offences 16.1 (a), 16.1 (b) and 16.1 (d) as per the CISI Membership Regulations, including several Code of Conduct principles.

Mr Gilligan has been expelled from CISI membership for a period of six years and two months.