Seminar

SEMINAR REPORT - 1 -ETHICS IN FINANCE

The world community is earnestly and eagerly seeking answers to

fundamental questions relating to ethics and morality in the conduct

of businesses, in the light of corporate fraud that has been taking

place from time to time. All professionals play a dual role that of

being the principal and an agent to their customers in discharge of

their functions. Often there is conflict of interest in every aspect of

professional life, which represents an ethical dilemma or dharma

sankat, and they arise fundamentally due to conflicting roles played

by individuals and institutions.

The emphasis is how to live and deal effectively with such

situations. A number of factors such as natural environment, work

culture, protecting the consumers at large and issue revolving

around accounting and finance principles come into consideration

and therefore it is important to understand the ethical issues in

business.

Ethics in general is concerned with human behavior that is

acceptable or "right" and that is not acceptable or "wrong" based on

conventional morality. General ethical norms encompass

truthfulness, honesty, integrity, respect for others, fairness, and

justice. They relate to all aspects of life, including business and

finance. Financial ethics is, therefore, a subset of general ethics.

Ethical norms are essential for maintaining stability and harmony in

social life, where people interact with one another. Recognition of

others' needs and aspirations, fairness, and cooperative efforts to

deal with common issues are, for example, aspects of social

behavior that contribute to social stability.

PUNJABI UNIVERSITY REGIONAL CAMPUS FOR INFORMATION TECHNOLOGY &MANAGEMENT,MOHALICREATED BY:- GIRISH KAPOOR (MBA II SEM. IV)

http://forum.belmont.edu/business/Ethics%20Graphic.jpg


In the process of social evolution, we have developed not only an

instinct to care for ourselves but also a conscience to care for

others. There may arise situations in which the need to care for

ourselves runs into conflict with the need to care for others. In such

situations, ethical norms are needed to guide our behavior.

As Demsey (1999) puts it: "Ethics represents the attempt to

resolve the conflict between selfishness and selflessness;

between our material needs and our conscience."

Ethical dilemmas and ethical violations in finance can be attributed

to an inconsistency in the conceptual framework of modern

financial-economic theory and the widespread use of a principal-

agent model of relationship in financial transactions. The financial-

economic theory that underlies the modern capitalist system is

based on the rational-maximizer paradigm, which holds that

individuals are self-seeking (egoistic) and that they behave

rationally when they seek to maximize their own interests.

The principal-agent model of relationships refers to an arrangement

whereby one party, acting as an agent for another, carries out

certain functions on behalf of that other. Such arrangements are an

integral part of the modern economic and financial system, and it is

difficult to imagine it functioning without them.

The behavioral assumption of the modern financial-economic theory

runs counter to the ideas of trustworthiness, loyalty, fidelity,

stewardship, and concern for others that underlie the traditional

principal-agent relationship. The traditional concept of agency is

based on moral values. But if human beings are rational

maximizers, then agency on behalf of others in the traditional sense

is impossible.




As Duska (1992) explains it: "To do something for another in

a system geared to maximize self-interest is foolish. Such an

answer, though, points out an inconsistency at the heart of

the system, for a system that has rules requiring agents to

look out for others while encouraging individuals to look out

only for themselves, destroys the practice of looking out for

others".

The ethical dilemma presented by the problem of conflicting

interests has been addressed in some areas of finance, such as

corporate governance, by converting the agency relationship into a

purely contractual relationship that uses a carrot-and-stick approach

to ensure ethical behavior by agents.

In corporate governance, the problem of conflict between

management (agent) and stockholders (principal) is described as an

agency problem. Economists have developed an agency theory to

deal with this problem. The agency theory assumes that both the

agent and the principal are self-interested and aim to maximize

their gain in their relationship.

A simple example would be the case of a store manager acting as

an agent for the owner of the store. The store manager wants as

much pay as possible for as little work as possible, and the store

owner wants as much work from the manager for as little pay as

possible.

This theory is value-free because it does not pass judgment on

whether the maximization behavior is good or bad and is not

concerned with what a just pay for the manager might be. It drops

the ideas of honesty and loyalty from the agency relationship




because of their incompatibility with the fundamental assumption of

rational maximization.

"The job of agency theory is to help devise techniques for

describing the conflict inherent in the principal-agent

relationship and controlling the situations so that the agent,

acting from self-interest, does as little harm as possible to

the principal's interest" (DeGeorge, 1992).

The agency theory turns the traditional concept of agency

relationship into a structured (contractual) relationship in which the

principal can influence the actions of agents through incentives,

motivations, and punishment schemes. The principal essentially

uses monetary rewards, punishments, and the agency laws to

command loyalty from the agent.

Most of our needs for financial services— management of retirement

savings, stock and bond investing, and protection against unfore-

seen events, to name a few—are such that they are better entrusted

to others because we have neither the ability nor the time to carry

them out effectively. The corporate device of contractualization of

the agency relationship is, however, too difficult to apply to the

multitude of financial dealings between individuals and institutions

that take place in the financial market every day.

Individuals are not as well organized as stockholders, and they are

often unaware of the agency problem. Lack of information also

limits their ability to monitor an agent's behavior. Therefore, what

we have in our complex modern economic system is a paradoxical

situation: the ever-increasing need for getting things done by others

on the one hand, and the description of human nature that

emphasizes selfish behavior on the other.

This paradoxical situation, or the inconsistency in the foundation of

the modern capitalist system, can explain most of the ethical




problems and declining morality in the modern business and finance

arena.

Finance and Accounts is perhaps the only business function which

accepts responsibility to act in public interest. Hence, a finance and

accounting professional’s responsibility is not restricted to satisfy

the needs of any particular individual or organization. While acting

in public interest, it becomes imperative that the finance and

accounting professional adheres to certain basic ethics in order to

achieve his objective.

Until recently, various surveys conducted globally had ranked

finance and accounting professionals very high in terms of

professional ethics. However, various accounting scandals

witnessed during the past few years have put a serious question

mark on the role of the finance and accounting professional in

providing the right information for decision making both within and

outside their respective organisations.

In companies such as Enron, WorldCom, Tyco, Global Crossing ,

Adelphia, Quest, Xerox and most of the late dotcoms, the

accounting information used by the Finance Department was false

and misappropriated.




What was the role of finance and accounting professionals in all

these high profile failures? Of course there were a few professionals

who were directly involved in fraudulent activities, however, the

majority, at most of the times, refused to challenge what they had

already known.

Enron is a classic example of such behaviour. Months before

Enron Corp declared bankruptcy, an employee of the name of

Sherron Watkins sent the company’s top executive (Kenneth Lay) a

message which had detailed information of the accounting hoax in

the form of

the now famous ‘off the book liabilities’. However, instead of taking

note of what was mentioned in the message, the management of

the company demoted Sherron. It is well known now, that, like

Sherron, hundreds of finance and accounting employees at Enron

knew about the happenings but preferred to remain silent.

Hence, most of them did not lie, but neither did they disclose the

truth nor did they attempt to correct the misleading and confusing

information. Shouldn’t they have blown the whistle the way Sherron

did? Was the behaviour of these employees un ethical? Cases like

Enron exist in plenty e.g. World Com, Global Crossing, Xerox, Qwest

and many other companies have been known to have created

accounting entries with the sole purpose of making their financial

statements look attractive thereby inviting further investments from

unsuspecting individuals and organisations.

Ethics in Finance is a ground-breaking work in the emerging field of

finance ethics. The need for ethics in the personal conduct of

finance professionals and the operation of financial markets and

institutions can be seen in many. A broad range of practical issues

in the financial services industry, investment decision making, and

corporate financial management are explored, focusing on




standards of fairness in market transactions and the duties of

fiduciaries and agents in financial relationships. Among the topics

covered are unethical sales practices, personal trading by fund

managers, the socially responsible investment movement, insider

trading and program trading, the abuse of bankruptcy, and hostile

takeovers.

Ethics in Finance also contains a critical examination of conception

of the theory of the firm in finance and the financial objective of

firms. Ethics in Finance provides a rigorous analysis of ethical issues

in finance that is suitable for students of finance and business ethics

as well as anyone involved in financial activities.

The concept of Ethics has been derived from the Greek word Ethos.

The word Ethos imbibes within itself both individual behaviour and

community culture. Various individuals would be having different

opinions on the same subject because of which what is perceived as

right by one may be considered wrong by the other. Hence, doing

what one thinks is right, may not always be the right thing to do!

This is the essence of the term ‘Ethics’ which may be defined

as ‘those moral principles which guide the conduct of individuals’

Irrespective of the differences of opinions amongst individuals,

Ethical behavior implies such course of actions which are taken after

giving due thought to their impact on the society and other stake

holders.

Hence when accounting and finance professionals at Enron did not

report of the wrongs which they believed were being done at the

top, their behaviour amounted to being unethical in spite of the fact

that they were not directly involved in any of the fraudulent or




manipulative activities. In contrast, when Cynthia Cooper, Vice

President – Internal Audit of World Com found wrong accounting

entries resulting in inflated profits, she immediately reported the

matter to the Board of Directors, this, in spite of the fact that she

was reporting against seniors whom she had come to admire over

the past so many years of working together. These two examples

mentioned above provide an insight into the meaning of Ethical

dilemmas. Ethical Dilemmas exist when finance and accounting

professionals need to choose from amongst alternatives and there

are

(1) significant value conflicts among differing interests

(2) actual alternatives which can all be justified and

(3) significant consequences to all stakeholders.

Let us consider an example of finance and accounting professional

who has been asked to provide a profit forecast which needs to be

given to a banker for a much wanted loan to be utilized in launching

a new product. The company has not been doing well for the past

few years and without this loan there is a likelihood of its closing

down. However, the loan can only be availed if the banker is

convinced that the projected profitability shall be at least Rs

50,00,000 per annum. An optimistic projection of the profits shows

that if everything goes extremely well the company may be able to

make profits of Rs 50,00,000, however, a realistic assumption

provides a much lower figure.

In such a situation the concerned professional will need to resolve

the dilemma of the type of profit forecast to be provided to the

banker. In case he gives a realistic projection the company may not

get the loan and perhaps may need to close down. On the other

hand if he makes a optimistic projection, he may be misleading the

banker. There is no right answer to such a situation. Both actions

proposed have got there own risks.




The most frequently occurring ethical violations in finance relate to

insider trading, stakeholder interest versus stockholder interest,

investment management, and campaign financing. Business in

general and financial markets in particular are replete with

examples of violations of trust and loyalty in both public and private

dealings. Fraudulent financial dealings, influence peddling and

corruption in governments, brokers not maintaining proper records

of customer trading, cheating customers of their trading profits,

unauthorized transactions, insider trading, misuse of customer

funds for personal gain, mispricing customer trades, and corruption

and larceny in banking have become common occurrences.

Insider trading is perhaps one of the most publicized unethical

behaviors by traders. Insider trading refers to trading in the




securities of a company to take advantage of material "inside"

information about the company that is not available to the public.

Such a trade is motivated by the possibility of generating

extraordinary gain with the help of nonpublic information

(information not yet made public). It gives the trader an unfair

advantage over other traders in the same security. Insider trading

was legal in some European countries until recently. In the United

States, the 1984 Trading Sanctions Act made it illegal to trade in a

security while in the possession of material nonpublic information.

The law applies to both the insiders, who have access to nonpublic

information, and the people with whom they share such information.

Campaign financing in the United States has been a major source of

concern to the public because it raises the issue of conflict of

interest for elected officials in relation to the people or lobbying

groups that have financed their campaigns.

The United States has a long history of campaign finance reform.

The Federal Election Commission (FEC) administers and enforces

the federal campaign finance statutes enacted by the Congress

from time to time. Many states have also passed lobbying and

campaign finance laws and established ethics commissions to

enforce these statutes.




For a finance and accounting professional working

as consultant or auditor

A finance and accounting professional in public practice should take

reasonable steps to identify circumstances that could pose a conflict

of interest. Such circumstances may give rise to threats to

compliance with the fundamental principles.

For example, a threat to objectivity may be created when a

professional accountant in public practice competes directly with a

client or has a joint venture or similar arrangement with a major

competitor of a client.

For a finance and accounting professional working

as an employer




A finance and accounting professional has a professional obligation

to comply with certain fundamental principles which have been

detailed below. There may be times, however, when their

responsibilities to an employing organization and the professional

obligations to comply with the fundamental principles are in conflict.

Ordinarily, a finance and accounting professional should support the

legitimate and ethical objectives established by the employer and

the rules and procedures drawn up in support of those objectives.

Nevertheless, where compliance with the fundamental principles is

threatened, a finance and accounting professional must consider a

response to the circumstances.

As a consequence of responsibilities to an employing organization, a

finance and accounting professional may be under pressure to act

or behave in ways that could directly or indirectly threaten

compliance with the fundamental principles. Such pressure may be

explicit or implicit; it may come from a supervisor, manager,

director or another individual within the employing organization. A

finance and accounting professional may face pressure to:

Act contrary to law or regulation.

Act contrary to technical or professional standards.

Facilitate unethical or illegal earnings management strategies.

Lie to, or otherwise intentionally mislead (including misleading

by remaining silent) others, in particular:

♦ The auditors of the employing organization; or

♦ Regulators.

♦ Issue, or otherwise be associated with, a financial or non-financial

report that materially misrepresents the facts, including statements

in connection with, for example:

♦ The financial statements;




♦ Tax compliance;

♦ Legal compliance; or

♦ Reports required by securities regulators.

A creation of a proper ethical environment requires a proper

understanding of the reasons which lead to un ethical behaviour.

Four such reasons are discussed below.,

1. Emphasis on short term results . This is one of the

primary reasons which has led to the downfall of many companies

like Enron and WorldCom. Manipulating accounting entries to depict

good profitability can help companies raise further capital from the

market.

2. Ignoring small unethical issues : It is a known fact that

most often the compromises we make start small however they lead

us to large problems. Similarly, companies need to develop an

environment where small ethical lapses are taken seriously so that




they do not repeat in the future. Otherwise, toleration of such small

lapses could lead to larger problems.

3. Economic cycles : When Enron was doing well , no one had

bothered to understand its actual financial position. There were no

question marks on its financial statements. However, when the

economy took a downward turn, finance and accounting managers

took decisions which were compromises over the established code

of conduct. This was done to reflect a financial position which would

keep the investors in the market satisfied. All this resulted in a huge

crisis and the ultimate fall of this US Giant.

Hence, to prevent disclosure of ethical problems in times of

depression, company need to be extremely careful and vigilant

during good times.

4. Accounting rules : In the era of globalisation and massive

cross border flow of capital, accounting rules are changing faster

than ever before. The rules have become more complex and it is

difficult to identify deviations from these complex set of

requirements.

The complexity of these principles and rules and the difficulty

associated with identifying abuse are reasons which may promote

un ethical behaviour.




Certain fundamental principles need to be adhered with for

behaving in an ethical manner. These principles have been

summarised below;

1. The principle of Integrity

The dictionary meaning of integrity is veracity. Accordingly, the

principle calls upon all accounting and finance professionals to

adhere to honesty and straight forwardness while discharging their

respective professional duties. In addition the following acts of

responsibility would help comply with the Integrity principle,

a) Avoid being involved in activities which would impair the

goodwill of the organization




b) Communicate adverse as well as favourable information with

those concerned

c) Refuse any gift or favour which could influence actions taken

or to be taken

d) Refuse to get involved in any activity which would adversely

affect the achievement of an organizations objective.

e) Avoid conflicts and advise related parties on apparent

conflicts which could arise in the future.

2. The principle of objectivity

This principle requires accounting and finance professionals to stick

to their professional and financial judgement. They should not allow

bias,conflicting interests or undue influence of others to override

their business judgements . They should communicate information

fairly and objectively in such a way that the communication with he

end user is complete and transparent.

3. The principle of confidentiality

This principle requires practitioners of accounting and financial

management to refrain from disclosing confidential information

related to their work. Such information may be however be

disclosed to their subordinates and care should be taken that the

latter maintains confidentiality. The only exception to this principle

is when there are requirements to disclose information under a legal

obligation or because of some statutory ruling.

4. The principle of professional competence and

due care

Finance and accounting professionals have a need to update their

professional skills from time to time. This has assumed a greater

significance in the modern day competitive environment where

updated knowledge and skill shall ensure that the client or employer




receives competent professional services based upon current and

contemporary developments in the

related areas.

5. The principle of professional behaviour

This principle requires accounting and finance professionals to

comply with relevant laws and regulations and avoid such actions

which may result into discrediting the profession.

Ethical issues in the financial services industry affect everyone,

because even if one doesn’t work in the field, but one is a consumer

of the services. The public seems to have the perception that the

financial services sector is more unethical than other areas of

business. This misperception persists for several reasons.

First of all, the industry itself is quite large. It encompasses

banks, securities firms, insurance companies, mutual fund

organizations, investment banks, pensions funds, mortgage lenders

—any company doing business in the financial arena. Because of its




vast size, the industry tends to garner lots of headlines, many of

which tout its ethical lapses.

“This business that we’re talking about is really big. It is, to be

precise, $50 trillion in assets. It’s growing 8 percent a year, which is

more than twice as fast as the gross domestic product. “It’s also

highly profitable. The financial services sector of the S&P 500

represents 20 percent of this index’s market capitalization. These

companies are making a lot of money serving one.”

So, with “trillions of dollars of assets, billions of transactions every

year—every day probably—when a small percentage of them is

inappropriate, the absolute numbers are still pretty big.”

The industry is also highly regulated, so it’s likely that a higher

percentage of these bad transactions are identified and reported,

perhaps more so than in other less regulated industries. But ethical

lapses do occur, mainly five reasons why these misdeeds may

happen.

1) Self-interest sometimes morphs into greed and selfishness, which

is unchecked self-interest at the expense of someone else. This

greed becomes a kind of accumulation fever. “If one accumulate for

the sake of accumulation, accumulation becomes the end, and if

accumulation is the end, there’s no place to stop,”. The focus shifts

from the long-term to the short-term, with a big emphasis on profit

maximization.

For example, swaps (where two communication companies agree to

exchange the right to use excess bandwidth on their networks) fall

into this category. Each company recognizes the income generated

in the quarter earned and defers the expenses through capitalizing

them as an asset and logging the cost as a recognized expense over




time, resulting in an inflated bottom line. This is what happened at

Qwest during the first three quarters of 2001, when the company

was selling $870 million of capacity, while at the same time buying

$868 million of capacity. These swaps appeared to be round-trip

transactions, which served no purpose other than to inflate Qwest’s

revenues.

“Companies were making money out of their finance department—

not from selling products, not from doing what the company did, not

from fulfilling the company’s mission, but from playing around with

its asset mix,”.

2) Some people suffer from stunted moral development: “ This

happens in three areas: the failure to be taught, the failure to look

beyond one’s own perspective, and the lack of proper mentoring,”

Business schools too often reduce everything to an economic entity.

“They do this by saying the fundamental purpose of a business is to

make money, maximize profit, or the really jazzy words ‘maximize

shareholder value,’ or something like that. And it never gets

questioned. Now if the fundamental purpose never gets questioned,

the ethics never get questioned, because the fundamental purpose

of something gives one the reason for its existence.

It tells you whether one is doing it well or not. It's the ultimate

ethical question: What's it purpose?”

3) Some people equate moral behavior with legal behavior,

disregarding the fact that even though an action may not be illegal,

it still may not be moral. “One ought to remember that the reason

for all laws is that the moral agreement begins to break down, and

the way to get other people in line is to legislate so that we can

stipulate punishments,” . Yet some people contend that the only




requirement is to obey the law. They tend to ignore the spirit of the

law in only following the letter of the law.

For example, IRS regulations repeatedly single out actions with “no

legitimate business purpose” (like swaps.) “If one is doing things

with no legitimate business purpose in order to avoid taxation, what

is he doing? He is violating the spirit, is one not? One is staying

within the letter, but there’s no purpose there except to get one

around the law,” he said.

4) Professional duty can conflict with company demands. For

example, a faulty reward system can induce unethical behavior. “A

purely self-interested agent would choose that course of action

which contains the highest returns to himself or herself,” he said.

For example, consider the misguided practice of selling indexed

annuities to the elderly. If a company is paying a high commission

for that product, say 15 percent, versus a lower commission for a

more appropriate product, say 3 percent, a salesperson may

disregard the needs of the client and/or assume that the company

supports this product and its applicability by its willingness to pay

five fold the compensation. “Sooner or later, people are going to

give in to that temptation. The purely self-interested agent is just

responding to the reward system that is in place,”

“One needs to take a look at what one is rewarding.” In general,

organizations get exactly what they reward. They just don’t realize

that their rewards structures are encouraging dysfunctional or

counter-productive behavior or turn a blind eye to the outcome

5) Individual responsibility can wither under the demands of the

client. Sometimes the push to act unethically comes from the client.

How many people expect their accountants to pad their expenses

where possible? How many clients expect their insurance agents to




falsify their applications or claims? “That’s the temptation—you like

your client, you’ve gotten to know your client, you really want to

help your client out—that’s just another conflicting loyalty,”

Suggestions for improvements in the industry to encourage more

ethical behavior. “In the financial services industry, the main work is

that people who do business are, for the most part, highly ethical

people trying to do the right thing most of the time. Most of them

are trying to help their clients achieve their financial objectives. But

how could this be better, because clearly, even if one is right, there

are still a lot of issues and problems in the business?”

First of all, consumers need to be better informed. “It is the

responsibility to take control of their own financial security,” which

doesn’t mean one needs to know everything about the product one

is buying in advance, but “one should read enough to know what

some of the right questions are to ask.” Ask those insightful

questions of an advisor whom you know, trust, and who has the

proper credentials, if applicable.

Other suggestions included:

Incentive compensation better aligned with customers’

interests, rather than agents’

more industry trade associations supporting ethics initiatives

the Center for Ethics in Financial Services growing in influence

and impact

Ethics of CARE(CREDIT ANALYSIS ANDRESEARCH ENTERPRISES)

Integrity & Transparency : A commitment to be ethical,

sincere and open in our dealings.




Pursuit of excellence: A commitment to strive relentlessly

to constantly improve ourselves.

Fairness: Treat clients, employees and other stakeholders

fairly.

Independence: We pride our independence, are unbiased

and fearless in expressing our opinion

Thoroughness: We like to do rigorous analysis and research

on every assignment that we take.

Financial transactions typically take place in organized markets,

such as stock markets, commodities markets, future or options

markets, currency markets and the like. These markets presuppose

certain moral rules and expectations of moral behaviour. The most

basic of these is a prohibition against fraud and manipulation, but,

more generally, the rules and expectations for markets are




concerned with fairness, which is often expressed as a level playing

field. The playing field in financial markets can become “tilted” by

many factors, including unequal information, bargaining power and

resources.

In addition to making one-time economic exchanges, participants in

markets also engage in financial contracting whereby they enter

into long term relations. These contractual relations typically involve

the assumption of fiduciary duties or obligations to act as agents,

and financial markets are subject to un is itself an ethical value

because ethical conduct when fiduciaries and agents fail in a duty.

In the standard model of contracting, the terms of a contract specify

the conduct required of each party and the remedies for non

compliance. In short ,there is little ”Wiggle Room” in a well written

contract.

However, many contractual relations in finance and other areas fall

short of this ideal, because actual contracts are often vague,

ambiguous, incomplete or otherwise problematic. The result is

uncertainty and disagreement about what constitutes ethical (as

well as legal) conduct.

Much of the necessary regulatory framework for financial markets is

provided by law. The Securities Act of 1933 and the Securities

Exchange Commission (SEC) constitute the main regulatory

framework for markets in securities and particular financial

investment institutions, such as banks, mutual funds and pension

and insurance companies are governed by industry specific

legislation.

EQUITY AND EFFICIENCY




The main aim of financial market regulation is to ensure efficiency,

but markets can be efficient only when people have confidence in

their fairness and equity. Efficiency achieving the maximum output

with the minimum input-which is a simple definition of efficiency-

provides the general welfare. A society is generally better off when

capital markets, for example, allocate the available capital to its

most productive uses. People will participate in capital markets,

however, only if the markets are perceived to be fair, that is fairness

has value as a means to the end of efficiency.

FAIRNESS IN MARKETS

What constitutes fairness in financial markets? Fairness is not a

matter of preventing loses. Markets produce winners and losers and

in many cases the gain of some persons comes from an equal loss

to others (although market exchanges are typically advantageous to

both parties). In this respect, playing the stock market is like playing

a sport. The aim is not to prevent losses but only to ensure that the

game is fair. Still, there may be good reasons for seeking to project

individual investors from harm, even when the harm does not

involve unfairness. Just as bean balls are forbidden in baseball (but

playing hardball is okay), so too are certain harmful practices

prohibited in the financial market place.

The regulation of financial markets protects not only individual

investors, but also the general public. The stock market crash of

1929, which prompted the first securities legislation, profoundly

affected the entire country. Everyone is harmed when financial

markets do not fill their main purpose but become distorted by

speculative activity or disruptive trading practices. The deleterious

effect of stock market speculation is wryly expressed by John

Maynard Keynes’s famous quip: “when the capital development of a

country becomes a by-product of the activities of a casino, the job is




likely to be ill-done.” More recently, the question of whether junk

bonds or programs trading pose risks to the stability of the financial

markets has been a subject of dispute.

The possible ways in which individual investors and members of

society can be treated unfairly by the operation of financial markets

are many, but the main kinds of unfairness are the following:

Frauds and Manipulation:- One of the main purposes of securities

regulation is to prevent fraudulent and manipulative practices in the

sale of securities. The common law definition of fraud is the willful

misrepresentation of a material fact that causes harm to a person

who reasonably relies on the misrepresentation. Section 17(a) of

1933 Securities Act and Section 10(b) of the 1934 Securities

Exchange Act both prohibit anyone involved in the buying or selling

of securities from making false statements of a material fact,

omitting a fact that makes a statement of material facts misleading

or engaging in any practice or scheme that would serve to defraud.

Investors-both as buyers and as sellers- are particularly vulnerable

to frau because the value of financial instruments depends almost

entirely on information that is difficult to verify. Much of the

important information is in the hands of issuing firm and so

antifraud provisions in securities law place an obligation not only on

buyers and sellers of a firm’s stock, for example, but also on the

issuing firm. Thus, a company that fails to report bad news may be

committing fraud, even though the buyer of that company’s stock

buys it a previous owner who may or may not be aware of the news.

Insider trading is prosecuted as a fraud under section 10(b) of the

Securities Exchange Act on the grounds that any material non public

information ought to be revealed before trading.




Manipulation generally involves the buying or selling of securities for

the purpose of creating a false or misleading impression about the

direction of their price so as to induce other investors to buy or sell

the securities. Like fraud, manipulation is designed to decive others,

but the effect is achieved by the creation of false or misleading

appearances rather than by false or misleading representations.

Fraud and manipulation are addressed by mandatory disclosure

regulations as well as by penalties for false and misleading

statements in any information released by a firm. Mandatory

disclosure regulations are justified, in part, because they promote

market efficiency. Better informed investors will make more rational

investment decisions and they will do so at lower overall cost. A

further justification, however, is the prevention of fraud and

manipulation under the assumption that good information drives out

bad. Simply put, fraud and manipulation are more difficult to

commit when investors have easy access to reliable information.

Equal information:- a “level playing field” requires not only that

everyone play by the same rules, but also that they be equally

equipped to compete. Competition between parties with very

unequal information is widely regarded as unfair because the

playing field is tilted in favor of the player with superior information.

When people talk about equal information, however they may mean

that the parties to a trade actually possess the main information or

have equal access to information.

That everyone should posses the same information is an

unrealizable ideal and actual markets are characterized by great

information asymmetries. The average investor cannot hope to

compete on equal terms with a market pro and even pros often

possess different information that leads them to make different

investment decisions. Moreover, there are good reasons for




encouraging people to acquire superior information for use in trade.

Consider stock analysts and other savvy investors who spend

considerable time,effort and money to acquire information. Not only

are they ordinarily entitled to use this information for their own

benefit (because it represents a return on an investment), but they

perform a service to everyone by ensuring that stocks are

accurately priced.

The possession of unequal information strikes us as unfair, then only

when the information has been illegitimately acquired or when its

use violates some obligation to others. One argument against

insider trading, for example, holds that an insider has not acquired

the information legitimately but has stolen( or “misappropriated”)

information that rightly belongs to the firm. In this argument, the

wrong fullness of insider trading consists not in the possession of

unequal information but in violating a moral obligation not to steal

or a fiduciary duty to serve others. Insider trading can also be

criticized on the grounds that others do not have the same access to

the information, which leads us to the second sense of equal

information, namely equal access.

The trouble with defining equal information as having equal access

to information is that the notion of equal access is not absolute but

relative. Any information that one person possesses could be

acquired by another with enough time, effort and money. An

ordinary investor has access to virtually all of the information that a

stock analyst uses to evaluate a company’s prospects. The main

difference is that the analyst has faster and easier access to

information because of an investment in resources and skills.

Anyone else could make the same investment and thereby gain the

same access-or a person could simply “buy” the analyst’s skilled

services. Therefore, accessibility is not a feature of information itself




but a function of the investment that is required in order to obtain

information.

Although efficiency and fairness both support attempts to reduce

information asymmetries in financial markets, exactly what fairness

or justice requires is not easy to determine. Consider, for example,

whether a geologist, who concludes after careful study that a

widow’s land contains oil, would be justified in buying the land

without revealing what he knows. A utilitarian could argue that

without such opportunities, geologists would not search for oil and

so society as a whole is better off if such advantage taking is

permitted. In addition, the widow herself, who would be deprived of

a potential gain, is better off in a society that allows some

exploitation of superior knowledge. A difficult task for securities

regulation, then is drawing a line between fair and unfair advantage

taking when people have unequal access to information.

Equal Bargaining Power:- Generally, agreements reached by

arm’s-length bargaining are considered to be fair, regardless of the

actual outcome. A trader, who negotiates a futures contract that

results in a great loss for example, has only himself or herself to

blame. However, the fairness of bargained agreements assumes

that the parties have relatively equal bargaining power. Unequal

bargaining power can result from many sources- including unequal

information, which is discussed above-but other sources include the

following factors.

A) Resources:- In most transactions, wealth is an advantage. The

rich are better able than the poor to negotiate over almost all

matters. Prices of groceries in low income neighborhoods are

generally higher than those in affluent areas, for example,

because wealthier customers have more options. Similarly,

large investors have greater opportunities. They can be better

diversified; they can bear greater risk and thereby obtain




higher leverage, they can gain more from arbitrage through

volume trading; and they have access to investments that are

closed to small investors.

B) Processing Ability:- Even with equal access to information,

people vary enormously in their ability to process information

and to make informed judgments. Unsophisticated investors

are ill advised to play the stcok market and even more so to

invest in markets that only professional understand. Fraud

aside, financial markets can be dangerous places for people

who lack an understanding of risks involved. Securities firms

and institutional investors overcome the problem of people’s

limited processing ability by employing specialists in different

kinds of markets and the use of computers in program trading

enables these organizations to substitute machine power for

gray matter.

C) Vulnerabilities:- investors are only human and human beings

have many weaknesses that can be exploited. Some

regulation is designed to protect people from the exploitation

of their vulnerabilities. Thus, consumer protection legislation

often provides for “cooling off” period during which shoppers

can cancel an impulsive purchase. The requirements that a

prospectus accompany offers of securities and that investors

be urged to read the prospectus carefully serve to curb

impulsiveness.

Efficient Pricing:- Fairness in financial markets includes efficient

prices that reasonably reflect all available information. A

fundamental market principle is that the price of securities should

reflect their underlying value. The mandate to ensure “fair and

orderly” markets- set forth in Securities Exchange Act of 1934- has

been interpreted to authorize invention to correct volatility or

excess price swings in stock markets. Volatility that results from a




mismatch of buyers and sellers is eventually self correcting, but in

the meantime, great harm may be done by inefficient pricing.

Individual investors may be harmed by buying at too high a price or

selling at too low price during periods of mispricing. Volatility also

affects the market by reducing investor confidence, thus driving

investors away and some argue that the loss of confidence

artificially depress stock prices. At its worst, volatility can threaten

the whole financial system.




There are many issues to consider when deciding to invest ethically.

This section seeks to explain more about these issues and provide

clarification on the wide range of strategies and methodologies

employed by fund managers when deciding ethical strategies. This

should be used in conjunction with our inter-active tools to assist

you in deciding on the most appropriate asset allocation when

considering which ethical funds to invest in.

What is ethical investment?

Ethical Investment has been defined as putting your money where

your morals are, or investing according to your beliefs. The term

"ethical investment" has been in circulation for over 20 years, since

the first ethical fund was launched in 1984. The idea behind the

ethical philosophy is that the fund manager will pick companies that

have the potential to do well both socially and financially. The roots

of SRI can be traced back to the nineteenth century where religious

orders such as Quakers and Methodists were concerned with issues

such as temperance and fair employment. At the beginning of the

1900s the Methodist Church decided to invest in the stock market

whilst specifically avoiding companies involved in alcohol and

gambling. This trend accelerated as more churches, charities and

individuals began to take ethical considerations into account when

investing. The first ethical fund in the UK was launched in 1984 by

Friends Provident.

Ethical investment allows individuals, companies and charities to

invest in a socially responsible way, without compromising their




beliefs and principles. Most investment wrappers (ISAs, pensions

etc) will allow you to choose a fund that suits your beliefs, so that

one can make a positive statement with their money. The careful

selection processes involved in ethical investment can help to

identify companies that have the potential to do well, both socially

and financially. An ethical fund manager will judge stocks on both

their positive and negative attributes, examples of which are shown

below:

A) Government legislation of pension funds have contributed to

making ethical investment an issue for pensioneer trustees.

Pensioneer trustees now have to disclose the extent to which social,

ethical and environmental issues are taken into account when

constructing fund asset allocations.

Ethical fund managers now have considerable influence in the policy

making decisions of multinational companies. This makes running a

business without a robust SRI policy is against the commercial

interest of companies who can be held to account by shareholder

engagement.

Companies who attract negative publicity and fines because of poor

ethical practices will are increasingly in the spotlight and will under

perform. Well run companies with a good SRI policy will not be

tarnished by future issues and are likely to be attrative for investors

along with start-up companies producing sustainable energy

products as alternatives to relying on unsustainable fossil fuels.

B) Investing in environmental solutions:- There is growing

acceptance that environmental problems are not going to

disappear. In fact, current trends show that they are

growing in importance. Green investment focuses on investing in

companies responding to environmental challenges, either by




developing a product or service which solves an environmental

problem, or by working to limit their impact on the environment.

Green investment seeks competitive advantage by spotting trends

in environmental technologies at an early stage.

The massive increase in environmental regulation over recent

decades has fuelled a greater understanding of green issues. For a

growing number of companies these regulations represent a growth

market largely unaffected by economic cycles. Increased consumer

awareness for environmental issues creates new market for

products such as organic food or renewable energy.

C) Retail:- Companies that put principles and systems in place to

deal with supply chain issues such as child labour and sustainable

timber are, for example, GUS and Argos. Sainsbury was named

Organic Supermarket of the year from 2002 to 2004 by the UK Soil

Association as an example of a company embracing the use of

organic and fair-trade products. US food retailer, Wholefoods

Market, specialises in organic foods.

D) Clean energy:- With an increasing focus

on climate change and energy security,

over 48 countries worldwide have

developed policies promoting renewable

energy. Global energy demand is

expected to rise over 50% by 2030 according to the International

Energy Agency. Investments are made in technologies such as wind,

solar and fuel cells, as well as emissions reduction.

E) Sustainable living:- Rising obesity and a focus on food quality

have resulted in health-conscious consumers paying more attention

to the food they buy and what they eat. Sales of organic food are

now worth more than £1.12bn to UK retailers and the market is




growing at twice the rate of the general grocery market. Combined

with an ageing population, the trend for healthy lifestyles has

created investment opportunities in organic food, complimentary

medicines and healthcare.

F) Environmental Services:- Increasing health, safety and

environmental regulation across the globe has resulted in new

markets for companies providing solutions to environmental and

social problems. Examples include environmental consultancies and

companies providing specialist equipment that minimises the risk of

safety incidents.

G) Long-term performance from environmental solutions:- The

publication of the World Energy Outlook in November 2005 by the

International Energy Agency (IEA) prompted wide-ranging

international press coverage. It highlighted the need to reduce our

global dependence on fossil fuels. While environmental concerns, in

particular climate change, have been central to this debate, the

issue that has dominated headlines of late is the concern over the

long-term sustainability of non-renewable fossil fuels. This is

particularly so in light of an increase in demand for this type of

energy from countries such as China and India. Unsustainable

energy trends means alternatives must be found In its latest World

Energy Outlook, the IEA stated that global energy demand is

expected to rise by more than 50% by 2030. The Agency warned

that current trends are unsustainable and that if renewable energy

sources are not tapped, oil prices will soar on increased demand and

greenhouse gas emissions will rise by an estimated 52% by 2030.

H) Increased legislation will mean further growth opportunities:- As

concern grows over global greenhouse gas emissions, governments




around the world are setting policy initiatives to promote and

encourage the development and use of cleaner energy. Examples

include the EU Renewable Energy Directive and EU Emissions

Trading Scheme. The Chinese government has stated that 15% of

all China's energy must come from sources other than fossil fuels by

2020. The successful outcome of the recent climate change talks in

Montreal has sent a clear signal that the future lies in clean and

more sustainable technologies.

The growth potential of renewable energy sources will attract a wide

investment audience As businesses embrace these changes there

will be more opportunities for growth in this sector. Fifteen years

ago there were no quoted companies operating in the alternative

energy sector. Now there are over 75 companies worldwide

operating in either the solar, wind, or fuel cell area and many more

at an unquoted level. These companies are of interest to all

investors, not just those with an ethical focus.

Investing in environmental solutions is becoming

increasingly important to all investors. Whilst

climate change is the most prominent

environmental issue in the news at the moment,

there are many other reasons why a green

approach to investing can pay for investors. Over

the last 30 years environmental issues on a

broader scale have increasingly moved to centre stage as there is

wide acceptance that environmental problems are not going to

disappear. Other environmental problems, particularly those

associated with scarcity of water, natural resources and pollution,

are believed to be amongst some of the greatest issues facing the

world today. From an investment perspective, the need to reduce

dependence on fossil fuels means that the renewable energy

industry is a long-term structural-growth story.




I) Environment policy delivers improvements:- Environment policy

has been seen as one of the success stories of the European Union

bringing improvements in areas such as cleaner air and safer

drinking water. In the UK, DEFRA (the Department of the

Environment, Food and Rural Affairs) is responsible for

approximately 30% of all legislation coming from Europe, more than

any other government department. In addition to increasing

legislation, enforcement against offenders is also being stepped up

In the US, federal initiatives like the Superfund program, which aims

to clean up hazardous waste sites, have raised the financial stakes

for businesses. This pattern is being repeated around the world. For

example, in its latest five year plan, China announced a significant

increase in environmental and health and safety regulation. These

issues are set to remain high on the political agenda.

J) Environmental consultants:- The trend for increasing regulation

creates opportunities for consultancies. Their specific knowledge

and expertise allows them to provide advice and develop solutions

for companies who are subject to regulation and don't have

sufficient expertise in-house. Wind energy is essential if the UK

Government is going to meet its target of 20% reduction in carbon

dioxide emissions by 2010. This rapidly growing sector of the global

electricity generation market and has averaged 28% annual growth

for the past five years. A key new area of growth in the next few

years is off-shore wind power.




FUND RAISING EXECUTIVE

A. They shall be responsible for conducting activities in

accordance with accepted professional standards of accuracy,

truth and good faith.

B. They shall encourage institutions they serve:

To conduct their affairs in accordance with accepted

principles of sound business and financial management,

and accounting procedures

To use donations only for the donors' intended purposes.

To comply with applicable local, provincial and federal

laws.

C. They shall recommend to the institutions they serve, only

those fund-raising goals which they believe can be achieved,

based on their professional experience, and an investigation,

and rational analysis of the facts.




D. They shall work for salary, retainer or fee, not a commission. If

employed by a fund-raising organization, the organization

shall operate in its client/consultant relationship on the basis

of a predetermined fee, and not a percentage of funds raised.

E. They shall make full disclosure to employers, clients or, if

requested, potential donors, all relationships which might pose

or appear to pose possible conflicts of interest. As fundraising

executives they will neither seek, nor accept, "finder's fees".

F. They shall hold confidential, and leave intact, all lists, records

and documents, acquired in the service of current or former

employers, and clients.

G. The public demeanor shall be such, as to bring credit to the

fund-raising profession.

UNDERWRITER

A. They shall provide advice and service which are in the

client's best interest.

One who possessing a specific body of knowledge which

is not possessed by the general public has an obligation

to use that knowledge for the benefit of the client and to

avoid taking advantage of that knowledge to the

detriment of the client.

In a conflict of interest situation the interest of the client

must be paramount.




They must make a conscientious effort to ascertain and

to understand all relevant circumstances surrounding

the client.

They have to accord due courtesy and consideration to

those engaged in related professions who are also

serving the client.

They have to give due regard to any agent principal

relationship which may exist between the member and

such companies as he may represent.

B. They shall respect the confidential relationship existing

between client and member.

Competent advice and service may necessitate the client

sharing personal and confidential information with the

member. Such information is to be held in confidence by the

member unless released from the obligation by the client.

C. They shall continue his education throughout his

professional life.

To advise and serve competently, a member must continue to

maintain and to improve his professional abilities.

Continuing Education includes both the member adding to his

knowledge the practice of his profession; and, the member

keeping abreast of changing economic and legislative

conditions which may affect the financial plans of the insuring

public.




They may continue his education through formal or informal

programs of study or through other professional experiences.

D. They shall render continuing advice and

service.

Advice and service, to be competent, must be ongoing as the

client's circumstances change and as these changes are made

known to the member.

A client with whom a member has an active professional

relationship is to be informed of economic and legislative

changes which relate to the client-member relationship.

To enhance the public regard for professional designations

and allied professional degrees held by members .

E. A member shall obey all laws governing his business

or professional activities.

Business activities are non-personal activities carried on

outside the life insurance community; professional activities

are non-personal activities carried on within the life insurance

community.

A member has a legal obligation to obey all laws applicable to

his business and professional activities.

F. They shall avoid activities which detract from the

integrity and professionalism.

Activities which could present a violation of this Profession

might include:




(1) Failure to obey a law unrelated to the member's business or

professional activities.

(2) Impairing the reputation of another practitioner.

(3) Unfairly competing with another practitioner.

(4) Actions which result in the discrediting their own reputation.

FINANCIAL ANALYST

A. Act with integrity, competence, diligence, respect, and in an

ethical manner with the public, clients, prospective clients,

employers, employees, colleagues in the investment

profession and other participants in the global capital

markets.

B. Place the integrity of the investment profession and the

interests of clients above their own personal interests.

C. Use reasonable care and exercise independent professional

judgment when conducting investment analysis, making

investment recommendations, taking investment actions, and

engaging in other professional activities.

D. Practice and encourage others to practice in a professional

and ethical manner that will reflect credit on themselves and

the profession.

E. Promote the integrity of and uphold the rules governing,

capital markets.

F. Maintain and improve their professional competence and

strive to maintain and improve the competence of other

investment professionals.




AUDITOR

A) Integrity

Shall perform their work with honesty, diligence, and

responsibility.

Shall observe the law and make disclosures expected by the

law and the profession.

Shall not knowingly be a party to any illegal activity, or

engage in acts that are discreditable to the profession of

internal auditing or to the organization.

Shall respect and contribute to the legitimate and ethical

objectives of the organization.

B) Objectivity

Shall not participate in any activity or relationship that may

impair or be presumed to impair their unbiased assessment.

This participation includes those activities or relationships that

may be in conflict with the interests of the organization.

Shall not accept anything that may impair or be presumed to

impair their professional judgment.

Shall disclose all material facts known to them that, if not

disclosed, may distort the reporting of activities under review.

C) Confidentiality

Shall be prudent in the use and protection of information

acquired in the course of their duties.

Shall not use information for any personal gain or in any

manner that would be contrary to the law or detrimental to

the legitimate and ethical objectives of the organization.

D) Competency




Shall engage only in those services for which they have the

necessary knowledge, skills, and experience.

Shall perform internal auditing services in accordance with the

International Standards for the Professional Practice of

Internal Auditing.

Shall continually improve their proficiency and the

effectiveness and quality of their services.

FINANCIAL PLANNERS

A) They should endeavor as professionals to place the public

interest above their own.

B) They should seek continually to maintain and improve

their professional knowledge, skills, and competence.

C) They should obey all laws and regulations and avoid any

conduct or activity which could cause unjust harm to those

who rely upon the professional judgment and skill of the

members.

D) They should be diligent in the performance of their

occupational duties.

E) They should assist in improving the public understanding

of financial planning.

F) They should assist in maintaining the integrity of the

Code of Professional.

BANK LOAN & CREDIT OFFICERS

There are two cardinal principles in the exchange of credit

information: confidentiality and accuracy of inquiries and replies.




This includes the identity of inquirers and sources which cannot be

disclosed without their permission. Adherence to these and the

other principles embodied in this Code is essential, since offenders

jeopardize their privilege to participate further in the exchange of

credit information.

Confidentiality, as it is used here, is based on the reliance placed

upon the fidelity of another with whom information is being

exchanged. A trust is placed in all parties involved that the

information has been requested for a legitimate purpose and will not

be used indiscriminately. When conducting investigations, the

identity of the Inquirer should not be divulged without its

authorization. Similarly, the identity of the source of the information

should not be made known without its authorization. The facts

presented must be accurate because the bank reference is one of

the most pertinent sources of credit information. When discussing

data, favorable or unfavorable, the responding bank must give a

reply that is restricted to or based on fact. If a discrepancy is

discovered within a reasonable time after an inquiry has been

answered and is considered to be significant in relation to the

purpose of the inquiry, it is prudent and ethical that the discrepancy

be disclosed to the inquirer.

It is expected that, as a matter of professional courtesy, no liability

will be attached to or result from the good faith exchange of

information. If the information is for a customer, it should be

screened according to the customer's needs, credit sophistication,

and ability to handle the information discreetly.

Adherence to these and the other principles embodied in this Code

of Ethics is essential. Violations of the Code could damage the

reputation of offending banks and individuals and may have an

adverse effect on the customer. If banks or individuals demonstrate




an inability and/or unwillingness to handle and exchange credit

information responsibly, they risk losing the privilege.

Each inquiry should specifically indicate its purpose and the amount

involved. One of the most important elements of an inquiry is its

purpose. The bank receiving the inquiry has a right to know why the

information is needed. If no purpose is given, the bank has no

obligation to respond. Knowing and understanding the purpose of an

inquiry places the recipient in a better position to respond with the

type and amount of information needed to satisfy the inquirer.

When the purpose of the inquiry is solicitation, acquisition, merger,

competition, or existing or intended legal action, reply is at the

discretion of the bank of account.

The inquirer should state the initial steps taken, as well as the

information on hand, in order to avoid duplication of effort. Inquiries

may be initiated either by telephone or in writing. In the interest of

timeliness, many member banks regularly accept telephone

inquiries. The legitimate use of credit information is to assist an

inquirer who expects to extend credit or otherwise rely on the

subject of the inquiry in business dealings. An inquiry should not be

answered without first determining its legitimacy and establishing

the identity of the inquirer.

For example, when receiving a telephone inquiry, information

should not be disclosed on the first call unless the inquirer is known

and identified. A return call may be used to establish the identity of

the inquirer.

In the majority of instances, a specific amount is involved in the

transaction which generates an inquiry. When initial trade credit is

involved and no amount is established, the inquiring party should be

asked for the normal size of its transactions. A range of figures such




as $500-$1,000 or $50,000-$60,000 is acceptable. It is unacceptable

to use fictitious figures or to inflate the amount involved to induce

the responding bank to provide details beyond what may be

necessary to answer the inquiry suitably. If for some reason there is

no amount involved, the inquirer should state this in a manner

which would logically satisfy the respondent as to the overall

purpose of the inquiry. A proper inquiry should contain the following:

A) SUBJECT: The subject of the inquiry should be identified as

completely as possible including full name, address, and names of

the principals.

B) PURPOSE: The reason for the inquiry should be given in

sufficient detail to allow the recipient to make an appropriate

response.

C) EXPERIENCE: If the inquirer has had experience with the

subject, a summary of that experience should be provided. Doing

this creates a true exchange of information and helps to eliminate

duplication of effort.

D) REQUIREMENTS: The inquirer should be specific about the

information required to satisfy the needs of the inquiry, such as

deposit relationships, loan experience, financial information,

assessment (of) management, etc.

E) OTHER: Any other factors relevant to the inquiry should be

disclosed.

Responses should be prompt and disclose sufficient material facts

commensurate with the purpose and amount of the inquiry. Specific

questions should be given careful and frank replies. Prompt and

accurate replies are signs of dependability and professionalism that

help the users of the information conduct business on a timely




basis. It is appropriate to respond using the same method in which

the request is presented, depending on the nature of the inquiry.

In light of the various corporate scandals mentioned above, the

following three points need tobe addressed for creating a sound

ethical environment in any company. They are,

1. Ensuring that employees are aware of their legal and

ethical responsibilities.

Ethical organisations would have policies to train and motivate

employees toward ethical behaviour. This would require initiation

from the top. A number of companies, both in the West and in India




have been known for their quality and soundness of their Ethics

programmes. Companies like Raytheon make ethics training

compulsory for everyone. Similarly Texas

Instruments has a well drafted Ethics programme from as long as

1961. In India Wipro was amongst the pioneers to establish an

organised set of beliefs which would guide business conduct. This

was done as early as 1970s. In the process the company has

established an Integrity manual which helps employees take ethical

decisions when faced with choices.

2. Providing a communication system between the

management and the employees so that any one in the

company can report about fraud and mismanagement

without the fear of being reprimanded

Ethical organisations need to provide facilities for employees

through which they could communicate with responsible positions

for reporting frauds, mismanagement or any other form of non

routine detrimental behaviour. In India Wipro has introduced a

helpline comprising of senior members of the company who are

available for guidance on any moral, legal or ethical issues that an

employee of the company may face.

3. Ensuring fair treatment to those who act as whistle

blowers.

This is perhaps the most important and sensitive issue. When

Sherron had raised questions at Enron, she was demoted. Similar

fate would have met all those who had followed Sherron. Fair

treatment to whistle blowers is a basic necessity to check fraud. It is

re assuring that two of the three persons of the year, selected by

the popular Time magazine were accountants from Enron and World

Com who had dared to blow the whistle, however, needless to say

that the appreciation is much more needed from within the

company rather than outside.




The dynamic environment in which businesses operate today may

usher a broad range of circumstances because of which compliance

with the above mentioned fundamental principles may potentially

be threatened. Such threats may be classified as follows:




(a) Self-interest threats, which may occur as a result of the financial

or other interests of a finance and accounting professional or of an

immediate or close family member;

(b) Self-review threats, which may occur when a previous judgment

needs to be reevaluated by the finance and accounting professional

responsible for that judgment;

(c) Advocacy threats occur when a professional promotes a position

or opinion to the point that subsequent objectivity may be

compromised;

(d) Familiarity threats occur when a finance and accounting

professional has close relationships in the work environment and

such relationships impair his selfless attitude towards work.

(e) Intimidation threats occur when a professional may be prohibited

from acting objectively by threats, actual or perceived.

EXAMPLES OF CIRCUMSTANCES CREATING ABOVE

MENTIONED THREATS.

Circumstances leading to the actual happening of the various

threats are given below.

A) Self interest threat for finance and accounting

professionals working as consultants or auditors

A financial interest in a client or jointly holding a financial

interest with a client.

Undue dependence on total fees from a client.

Having a close business relationship with a client.

Concern about the possibility of losing a client.

Potential employment with a client.

Contingent fees relating to an assurance engagement.




B) Self interest threat for finance and accounting

professionals working as an employee

Financial interests, loans and guarantees in the company the

professional is working.

Incentive compensation arrangements

Inappropriate personal use f corporate assets.

Concern over employment security

Commercial pressure from outside the employing organisation

C) Self review threat for finance and accounting


The discovery of a significant error during a re-evaluation of

the work of the finance and accounting professional.

Reporting on the operation of financial systems after being

involved in their design or implementation.

Having prepared the original data used to generate records

that are the subject matter of the engagement.

A member of the assurance team being, or having recently

been, a director or Officer of that client.

A member of the assurance team being, or having recently

been, employed by the Client in a position to exert direct and

significant influence over the subject matter of the

engagement.

D) Self review threat for finance and accounting


Such threats occur when business decisions or data is subjected to

review and justification is required to be given by the same

professional who was responsible for taking such decisions or

preparing that data.

E) Advocacy threat for finance and accounting professionals

working as consultants or auditors




Promoting shares in a listed entity* when that entity is a

consultancy or a financial statement audit client.

Acting as an advocate on behalf of an assurance client in

litigation or disputes with third parties.

F) Advocacy threat for finance and accounting professionals

working as an employee.

When furthering the legitimate goals and objectives of their

employing organizations finance and accounting professionals may

promote the organization’s position, provided any statements made

are neither false nor misleading. Such actions generally would not

create an advocacy threat.

G) Familiarity threats for finance and accounting


A member of the engagement team having a close or

immediate family relationship with a director or officer of the

client.

A member of the engagement team having a close or

immediate family relationship with an employee of the client

who is in a position to exert direct and significant influence

over the subject matter of the engagement.

A former partner of the firm being a director or officer of the

client or an employee in a position to exert direct and

significant influence over the subject matter of the

engagement.

Accepting gifts or preferential treatment from a client, unless

the value is clearly insignificant.




Long association of senior personnel with the assurance client.

H) Familiarity threats for finance and accounting


A finance and accounting professional, in a position to

influence financial or non financial reporting or business

decisions having an immediate or close family member who is

in a position to benefit from that influence.

Long association with business contacts influencing business

decisions.

Acceptance of a gift or preferential treatment, unless the

value is clearly insignificant.

I) Intimidation threat for finance and accounting


Being threatened with dismissal or replacement.

Being threatened with litigation.

Being pressured to reduce inappropriately the extent of work

performed in order to reduce fees.

J) Intimidation threat for finance and accounting

professionals working as employees

Threat of dismissal or replacement of the finance and

accounting professional or a close or immediate family

member over a disagreement about the application of an

accounting principle or the way in which financial information

is to be reported for external use as well as for decision

making purposes.




A dominant personality attempting to influence the decision

making process, for example with regard to the exclusion of

irrelevant costs from projected cost estimates.

It is important to have safeguards which may increase the likelihood

of identifying or deterring unethical behavior. Such safeguards,

which may be created by the finance and accounting profession,

legislation, regulation or an employing organization, shall ensure an

ethical environment. Safeguards that may eliminate or reduce the

abovementioned threats to an acceptable level fall into two broad

categories:




(a) Safeguards created by the profession, legislation or regulation;

and

(b) Safeguards in the work environment.

A) Some of the safeguards created by the profession,

legislation or regulation are as follows

Educational, training and experience requirements for entry

into the profession.

Continuing professional development requirements.

Corporate governance regulations.

Professional standards.

Professional or regulatory monitoring and disciplinary

procedures.

External review by a legally empowered third party of the

reports, returns, communications or information produced by

concerned professionals.

B) Safeguards in the work environment are as follows.

The employing organization’s systems of corporate oversight

or other oversight structures.

The employing organisation’s ethics and conduct programs.

Recruitment procedures in the employing organisation

emphasizing the importance of employing high caliber

competent staff.

Strong internal controls.

Appropriate disciplinary processes.

Leadership that stresses the importance of ethical behavior

and the expectation that employees will act in an ethical

manner.

Policies and procedures to implement and monitor the quality

of employee performance.

Timely communication of the employing organisation’s

policies and procedures, including any changes to them, to all




employees and appropriate training and education on such

policies and procedures.

Policies and procedures to empower and encourage

employees to communicate to senior levels within the

employing organization any ethical issues that concern them

without fear of retribution.

While evaluating compliance with the fundamental principles, a

finance and accounting professional may be required to resolve a

conflict in the application of fundamental principles. The following

needs to be considered, either individually or together with others,

during a conflict resolution process,

(a) Relevant facts;




(b) Ethical issues involved;

(c) Fundamental principles related to the matter in question;

(d) Established internal procedures; and

(e) Alternative courses of action.

Having considered these issues, a finance and accounting

professional should determine the appropriate course of action that

is consistent with the fundamental principles identified. The

professional should also weigh the consequences of each possible

course of action. If the matter remains unresolved, the professional

should consult with other appropriate persons within the firm* or

employing organization for help in obtaining resolution. During

times where a matter involves a conflict with, or within, an

organization, finance and accounting professional should also

consider consulting with those charged with governance of the

organisation, such as the board of directors.

It may be in the best interests of the professional to document the

substance of the issue and details of any discussions held or

decisions taken, concerning that issue. If a significant conflict

cannot be resolved, a professional may wish to obtain professional

advice from the relevant professional body or legal advisors, and

thereby obtain guidance on ethical issues without breaching

confidentiality.

For example, a professional accountant may have encountered a

fraud, the reporting of which could breach the professional

accountant’s responsibility to respect confidentiality. The

professional accountant should consider obtaining legal advice to

determine whether there is a requirement to report.

If, after exhausting all relevant possibilities, the ethical conflict

remains unresolved, a professional should, where possible, refuse to




remain associated with the matter creating the conflict. The

professional may determine that, in the circumstances, it is

appropriate to withdraw from the engagement team or specific

assignment, or to resign altogether from the engagement, the firm

or the employing organization.

In the broadest sense, a fraud is a deception made for personal

gain. Fraud is a crime, and is also a civil law violation. Many hoaxes

are fraudulent, although those not made for personal gain are not

technically frauds. Defrauding people of money is presumably the

most common type of fraud.




In criminal law, fraud is the crime or offense of deliberately

deceiving another in order to damage them – usually, to obtain

property or services unjustly. Fraud can be accomplished through

the aid of forged objects.

Fraud can be committed through many methods, including mail,

wire, phone, and the internet (computer crime and internet fraud).

Bank fraud is a federal crime in many countries, defined as planning

to obtain property or money from any federally insured financial

institution. It is sometimes considered a white-collar crime.

Frauds in the financial sector can be categorized broadly as:

A) Frauds by insiders

B) Frauds by outsiders

FRAUDS BY INSIDERS FRAUDS BY OUTSIDERS

Rogue Traders Forged and Altered Cheque

Fraudulent Loans Stolen Cheque

Wire Fraud Accounting Fraud

Forged Documentation Bill Discounting Fraud

Uninsured Deposits Cheque kitting

Theft of Identity Payment Card Fraud

Demand Draft Fraud Booster Cheques

Stolen Payment Cards

Skimming Credit Card

Information

Impersonation

Fraudulent loan Application

Prime Bank Fraud

Fictious Bank Officer

Phishing




Money Laundering

Various Financial Frauds

J.P. Morgan Chase

J. P. Morgan Chase & Co. was formed with the merger of The Chase

Manhattan Corporation and J.P. Morgan & Co. Inc., What may have

seemed like an indicator of continued prosperity for this industry

giant instead brought hard times for the firm. A year after the

merger, energy provider Enron declared bankruptcy, and few banks

had as many dealings with them as J.P. Morgan Chase. They face

numerous lawsuits from their shareholders, those of Enron, and

other parties involved in the deals.

Why is J. P. Morgan accused of fraud?

Though Merrill Lynch’s involvement with Enron was publicized more

highly than that of other investment firms, the bankrupt energy

company is accused of receiving loans from many sources, one of

which was J.P. Morgan. This has led to several lawsuits.

One suit has been filed by insurance companies that stood to lose

money for insuring transactions between Enron and J.P. Morgan. The

insurance companies allege that they should not be liable for deals

that J.P. Morgan executives knew to be shams.

J.P. Morgan is also being sued in the Enron shareholder suit that

includes as defendants Enron executives, Arthur Andersen LLP, a

number of banks, and several law firms. Enron shareholders believe

that J.P. Morgan helped Enron take out loans that were disguised as

purchases and trades.




At the same time, J.P. Morgan faces lawsuits from its own

shareholders, who claim that the company didn’t properly inform

them of how much it stood to lose in its dealings with Enron.

Finally, a group of banks that combined to make an enormous loan

to Enron in its dying days is considering filing suit against J.P.

Morgan. At issue is whether or not J.P. Morgan organized the loan so

that it could be repaid for some of its loans to Enron, fully aware

that the company would soon declare bankruptcy.

What is the current status?

The lawsuit filed by the ten insurance companies has been settled.

The plaintiffs, originally on the hook for about $1 billion to J.P.

Morgan, have agreed to pay about 60 percent of it.

J.P. Morgan executives have been questioned about their roles in

the fall of Enron, but, to date, no criminal charges have been filed

against them.

Morgan Stanley

Morgan Stanley is one of the largest investment banking firms in

USA. The global securities market is one of Morgan Stanley’s

primary business arenas. The firm serves both individual and

institutional investors. Along with several other high-profile firms,

Morgan Stanley has recently endured a number of questions about

conflicts of interest and potential fraud.

When was the possible fraud discovered ?




Top Wall Street firms have recently been required to pay large fines

to regulators for alleged partiality in their stock reports to investors.

In December 2002, a preliminary agreement was reached with 12

U.S. investment banks in which they agreed to pay a combined total

of over 1 billion dollars. The Securities and Exchange Commission

(SEC) and state regulators brought accusations against the banks in

the preceding months, alleging that investment banks had let

conflicts of interest color their stock reports.

Morgan Stanley has also been individually targeted by the world’s

leading luxury item maker, LVMH. The leadership at LVMH has

accused Morgan Stanley of allowing a conflict of interest to interfere

with its research reporting. Gucci, a long-time rival of LVMH, has

close ties with Morgan Stanley. While LVMH claims that this

relationship caused Morgan Stanley to unfairly spin its stock reports

to investors, Morgan Stanley is vehemently denying any accusation

of fraud. The lawsuit by LVMH was filed in a French court in

November.

What type of fraud is alleged to have been committed ?

The charges filed by the SEC and state regulators against a host of

investment banks are roughly synonymous to the accusations

against Morgan Stanley by LVMH. Both claim that conflicts of

interest have contributed to dishonest stock reports to investors. If

LVMH wins its case against Morgan Stanley, it will be because it

shows convincing evidence that the securities firm put its interest in

Gucci ahead of its duty to present investors with an accurate picture

of stocks’ value.

Zurich Financial Services, Converium Holding AG

Settle Reinsurance Fraud Charges




The Securities and Exchange Commission today announced settled

civil securities fraud charges against Zurich Financial Services and

Converium Holding AG, now known as SCOR Holding (Switzerland)

AG, relating to finite reinsurance transactions. The SEC's orders find

that Zurich's former reinsurance group, which operated under the

name Zurich Re and was later spun off in 2001 as Converium,

designed three reinsurance transactions to make it appear that risk

had been transferred to third-party entities when, in fact, the risk

remained with Zurich-controlled entities.

According to the SEC's orders, Zurich Re — and later Converium —

improperly used reinsurance accounting for the transactions

enabling them to artificially inflate their performance figures. This

misconduct allowed Zurich to receive a significant windfall when it

spun off Converium in a December 2001 initial public offering.

Converium continued the fraudulent scheme following the IPO.

Zurich and Converium agreed to settle the SEC's charges without

admitting or denying the SEC's findings, and Zurich will pay a $25

million penalty.

WIPRO’S CODE OF ETHICS FOR PRINCIPAL AND

FINANCE OFFICERS:

Wipro’s Promise




“With utmost respect to Human Values, we promise to serve our

customer with Integrity, through Innovative, Value for Money

Solutions, by Applying Thought, day after day.”

Our promise is at the core of Corporate Governance Practice in

Wipro. In the Information Age, Information is the Key asset. As

custodians of Information and assets, the Code of Ethics for Principal

Officer and Finance Professionals is codified as under.

Applicability

The Code of Ethics applies to the Principal Officer and all the

employees in Finance Function in Wipro. The Principal Officer and all

the employees in the Finance Function are expected to abide by this

code as well as other applicable Wipro policies or guidelines. Any

violation of Wipro Code of Ethics may result in disciplinary action, up

to and including immediate termination.

Wipro’s Code of Ethics for Principal Officer and Finance

Professionals

I. Principle of Professional & Personal Integrity:

Act with honesty and integrity, avoiding actual or apparent

conflicts of interest in personal and professional relationships.

Confidential information acquired in the course of one's work

will not be used for personal advantage.

Achieve responsible use of and control over all assets and

resources employed or entrusted.

II. Principle of Propriety& Relevance of Information:

Provide all stakeholders with information that is accurate,

complete, objective, relevant, timely and understandable.




Respect the confidentiality of information acquired in the

course of one's work except when authorized or otherwise

legally obligated to disclose.

III. Principle of Compliance:

·Comply with rules and regulations of all Public Authorities in

all the geographies in which Wipro operates.

IV. Principle of Role models of Highest Standards of

Corporate Governance:

Act in good faith, responsibly, with due care, competence and

diligence, without misrepresenting material facts or allowing

one's independent judgment to be subordinated.

Share knowledge and maintain skills important and relevant to

stakeholders’ needs.

Proactively promote and be an example of ethical behavior as

a responsible partner among peers, in the work environment

and the community.

ECOLAB’S Code of Ethics for Senior Officers and

Finance Associates

In my role as a Senior Officer or Finance Associate at Ecolab, I have

adhered to and advocated to the best of my knowledge and ability

the following principles and responsibilities governing professional

conduct and ethics:

A) Act with honesty and integrity, avoiding actual or apparent

conflicts of interest in personal and professional relationships.

A "conflict of interest" exists when an individual's private




interests interfere or conflict in any way (or even appear to

interfere or conflict) with the interests of the Company.

B) Provide information that is full, fair, accurate, complete,

objective, relevant, timely and understandable, including in

and for reports and documents that the Company files with, or

submits to, the SEC and other public communications made

by the Company.

C) Comply with all applicable laws, rules and regulations of

federal, state and local governments, and other appropriate

private and public regulatory agencies.

D) Act in good faith, responsibly, with due care, competence and

diligence, without misrepresenting material facts or allowing

my independent judgement to be subordinated.

E) Respect the confidentiality of information acquired in the

course of business except when authorized or otherwise

legally obligated to disclose the information. I acknowledge

that confidential information acquired in the course of

business is not to be used for personal advantage.

F) Proactively promote ethical behavior among my associates at

the Company and as a responsible partner with industry peers

and associates.

G) Maintain control over and responsibly manage all assets and

resources employed or entrusted to me by Ecolab.

H) Adhere to and promote this Code of Ethics.




This Code of Ethics is intended to supplement the Ecolab Code of

Conduct and company policies regarding ethical practices in the

finance area. All procedures for upholding, enforcing, and complying

with the Code of Conduct are also applicable to this Code of Ethics.

The Ecolab Law Department should be asked to help interpret or

apply this Code as required.

In the end it can be said that approaches to dealing with ethical

problems in finance range from establishing ethical codes for

financial professionals to efforts to replace the rational-maximizer

(egoistic) paradigm that underlies the modern capitalist system by

one in which individuals are assumed to be altruistic, honest, and

basically virtuous.




It is not uncommon to find established ethical codes and ethical

offices in corporations and in financial markets. Ethical codes for

financial markets are established by the official regulatory agencies

and self-regulating organizations to ensure ethically responsible

behavior on the part of the operatives in the financial markets.

One of the most important and powerful official regulatory agencies

for the securities industry in the United States is the Securities and

Exchange Commission (SEC). It is in charge of implementing federal

securities laws, and, as such, it sets up rules and regulations for the

proper conduct of professionals operating within its regulatory

jurisdiction. Many professionals play a role within the securities

industry, among the most important of which are accountants,

broker-dealers, investment advisers, and investment companies.

Any improper or unethical conduct on the part of these professionals

is of great concern to the SEC, whose primary responsibility is to

protect investor interests and maintain the integrity of the securities

market.

The SEC can censure, suspend, or bar professionals who practice

within its regulatory domain for lack of requisite qualifications or

unethical and improper conduct. The SEC also oversees self-

regulatory organizations (SROs), which include stock exchanges, the

National Association of Security Dealers (NASD), the Municipal

Securities Rulemaking Board (MSRB), clearing agencies, transfer

agents, and securities information processors. An SRO is a

membership organization that makes and enforces rules for its

members based on the federal securities laws. The SEC has the

responsibility of reviewing and approving the rules made by SROs.

Other rule-making agencies include the Federal Reserve System,

the Federal Deposit Insurance Corporation (FDIC), and state finance

authorities. Congress has entrusted to the Federal Reserve Board




the responsibility of implementing laws pertaining to a wide range of

banking and financial activities, a task that it carries out through its

regulations. One such regulation has to do with unfair or deceptive

acts or practices. The FDIC has its own rules and regulations for the

banking industry, and it also draws its power to regulate from

various banking laws passed by Congress.

In addition to federal and state regulatory agencies, various

professional associations set their own rules of good conduct for

their members. The American Institute of Certified Public

Accountants (AICPA), the American Institute of Certified Planners

(AICP), the Investment Company Institute (ICI), the American Society

of Chartered Life Underwriters (ASCLU), the Institute of Chartered

Financial Analysts (ICFA), the National Association of Bank Loan and

Credit Officers (also known as Robert Morris Associates), and the

Association for Investment Management and Research (AIMR) are

some of the professional associations that have well-publicized

codes of ethics.

There has been an effort to address the ethical problems in business

and finance by reexamining the conceptual foundation of the

modern capitalist system and changing it to one that is consistent

with the traditional model of agency relationship. The proponents of

a paradigm shift question the rational-maximizer assumption that

underlies the modern financial-economic theory and reject the idea

that all human actions are motivated by self-interest. They embrace

an alternative assumption—that human beings are to some degree

ethical and altruistic—and emphasize the role of the traditional

principal-agent relationship based on honesty, loyalty, and trust.

Duska (1992) argues: "Clearly, there is an extent to which [Adam]

Smith and the economists are right. Human beings are self-

interested and will not always look out for the interest of others. But




there are times they will set aside their interests to act on behalf of

others. Agency situations were presumably set up to guarantee

those times."

The idea that human beings can be honest and altruistic is an

empirically valid assumption; it is not hard to find examples of

honesty and altruism in both private and public dealings. There is no

reason this idea should not be embraced and nurtured.

As Bowie (1991) points out: "Looking out for oneself is a natural,

powerful motive that needs little, if any, social reinforcement. . . .

Altruistic motives, even if they too are natural, are not as powerful:

they need to be socially reinforced and nurtured".

If the financial-economic theory accepts the fact that behavioral

motivations other than that of wealth maximization are both

realistic and desirable, then the agency problem that economists try

to deal with will be a nonproblem. For Dobson (1993), the true role

of ethics in finance is to be found in the acceptance of "internal

good" ("good" in the sense of "right" rather than in the sense of

"physical product"), which, he adds, is what classical philosophers

describe as "virtue"—that is, the internal good toward which all

human endeavor should strive. He contends: "If the attainment of

internal goods were to become generally accepted as the ultimate

objective of all human endeavor, both personal and professional,

then financial markets would become truly ethical"

Anand Shetty "Ethics in Finance". Encyclopedia of Business, 2nd

ed..FindArticles.com. 23 Jan. 2009. available


http://findarticles.com/p/articles/mi_gx5209/is_1999/ai_n19125703/pg_3



at:-http://findarticles.com/p/articles/mi_gx5209/is_1999/ai_n1912570

3

Anand Prakash Jangid(ACA, CISA,DISA, CISM, ACP), “LESSONS TO BE

LEARNT FROM THE WORLD’S BIGGEST BANKING FRAUD – SOCIETE

GENERALE”

Bowie, Norman E. (1991). "Challenging the Egoistic Paradigm."

Business Ethics Quarterly. 1. 1-4.

Bowie, Norman E., and Freeman, Edward R., eds. (1992). Ethics and

Agency Theory: An Introduction. New York: Oxford University Press.

Boatright R. John;(2003) “Ethics and the conduct of business” 4th

Edition, Pearson education. Pg. 339 to 368

DeGeorge, Richard T. (1992) "Agency Theory and the Ethics of

Agency." In Norman E. Bowie and Edward R. Freeman, eds. Ethics

and Agency Theory: An Introduction. New York: Oxford University

Press.

Dempsey, Mike. (1999). "An Agenda for Window-Dressing or for

Radical Change?"

http://panopticon.csustan.edu/cpa99/html/dempsy.html.

Dobson, John. (1993). "The Role of Ethics in Finance." Financial

Analysis Journal. November-December: 57-61.

Dobson John; H.Alford; Rowman & Littlefield,” Finance Ethics: the

rationality of virtue”; Lanham and Oxford, 1997, pp. 159; ISBN 0-

8476-8401-6 (cloth) 0-8402-4 (paper) available at

http://www.pust.edu/oikonomia/pages/genn/recensione.html

Duska, Ronald R. (1992). "Why Be a Loyal Agent? A Systematic

Ethical Analysis." In Ethics and Agency Theory: An Introduction.


http://www.pust.edu/oikonomia/pages/genn/recensione.html

http://panopticon.csustan.edu/cpa99/html/dempsy.html



Norman E. Bowie and Edward R. Freeman, eds., New York: Oxford

University Press.

Frowen, S.F. and McHugh, F.P., eds. (1995). ed. Financial Decision-

Making and Moral Responsibility. New York: Macmillan.

Goodpaster, Kenneth E. (1991). "Business Ethics and Stake-holder

Analysis." Business Ethics Quarterly. 1. 53-71.

Hartman P. Laura;(2004) ” Perspectives in business ethics”; Second

Edition; the Tata Mcgrawhill Companies; pg no. 582 to 645.

Nadler, Paul S. (1989). "Ethics and the Financial Community."

Secured Lender. January-February.

Internet Web Source:-

http://books.google.co.in/books?

id=BiEWtnbREV8C&dq=ethics+in+finance&source=bn&sa=X&oi=b

ook_result&resnum=4&ct=book-thumbnail

http://www.enotes.com/business-finance-encyclopedia/ethics-finance

http://www.ecolab.com/Investor/Governance/codeofethics.asp

http://www.scu.edu/ethics/practicing/focusareas/business/

financial-services.html

http://www.ibe.org.uk/teaching/Ethics%20and%20financial

%20services.pdf

http://www.careratings.com/content/aboutcare/vision.aspx

http://www.pressreleasepoint.com/zurich-financial-services-

converium-holding-ag-settle-reinsurance-fraud-charges


http://www.pressreleasepoint.com/zurich-financial-services-converium-holding-ag-settle-reinsurance-fraud-charges

http://www.pressreleasepoint.com/zurich-financial-services-converium-holding-ag-settle-reinsurance-fraud-charges

http://www.careratings.com/content/aboutcare/vision.aspx

http://www.ibe.org.uk/teaching/Ethics%20and%20financial%20services.pdf

http://www.ibe.org.uk/teaching/Ethics%20and%20financial%20services.pdf

http://www.scu.edu/ethics/practicing/focusareas/business/financial-services.html

http://www.scu.edu/ethics/practicing/focusareas/business/financial-services.html

http://www.ecolab.com/Investor/Governance/codeofethics.asp

http://books.google.co.in/books?id=BiEWtnbREV8C&dq=ethics+in+finance&source=bn&sa=X&oi=book_result&resnum=4&ct=book-thumbnail







Documents

Seminar