CSI has a responsibility to oversee the individuals who have been granted a CSI designation or fellowship. This oversight is carried out in the best interest of the public and the holders of a designation or fellowship. 

All designation and fellowship holders have attested to abide by a Code of Ethics. Adherence to the Code and this Ethical Misconduct Process is mandatory for all holders of a CSI designation or fellowship. A breach of the Code of Ethics can result in disciplinary action.

This document sets out the process a member of the public (the complainant) can follow to submit a complaint against a CSI designation or fellowship holder and the process to be followed for a designation or fellowship holder to self-declare any past or pending legal action. It also sets out the procedures followed by CSI to deal with complaints, self-declarations or other relevant information received on a designation or fellowship holder that relates to a possible breach of the Code of Ethics.

CSI is responsible for overseeing individuals who have requested or been granted a CSI designation or fellowship. This oversight is conducted in the best interest of both the public and the applicants or holders of the designation or fellowship.

All designation and fellowship applicants or holders have attested to abide by a Code of Ethics, including adhering to the Ethical Misconduct Process. A breach of the Code of Ethics, including failure to cooperate with the Ethical Misconduct Process can result in disciplinary action.

All designation and fellowship applicants are required to declare any historical or present criminal charges, legal actions, allegations of wrongdoing, or complaints involving them prior to being granted a designation. Designation and Fellowship holders must notify CSI of any criminal charges, legal actions, allegations of wrongdoing, or complaints initiated against them within 30 calendar days of occurrence or upon renewal of the credential, whichever comes first.

This document outlines the process that:

• members of the public can use to submit a complaint against a CSI designation or fellowship holder; and
• designation or fellowship applicants or holders must follow to self-declare any historical or present criminal charges, legal actions, allegations of wrongdoing, or complaints involving them.

CSI will follow-up to address complaints, self-declarations, or other relevant information received about a designation or fellowship applicant or holder that may indicate a breach of the Code of Ethics.

Applicants and holders of designations and fellowships are expected to comply with CSI investigations and follow the procedures detailed in this document. Failure to do so may result in additional breaches of the Code of Ethics and sanctions.

Definitions

Allegation

An assertion, regarding a breach of the Code of Ethics by an individual applying for or holding a CSI designation or fellowship, which remains unproven and requires verification through evidence.

Appeal Hearing

A formal proceeding conducted by the Appeal Panel.

Appeal Panel

The panel of members chosen to preside over an appeal hearing.

Appellant

The individual appealing a decision made by the Designation Ethics Committee (DEC).

Applicant

An individual who is pursuing a CSI designation or fellowship.

Business Days

Days on which normal business operations at CSI are conducted (Monday through Friday), except for statutory holidays.

Calendar Days

Any day, including weekdays, weekends, and statutory holidays.

Chair of the Designation Ethics Committee (DEC)

An individual nominated by the Designation Ethics Committee (DEC) and appointed by CSI to lead the Designation Ethics Committee, who reviews case files prior to committee meetings to determine the status for moving each file forward to the full committee. Where the Chair is absent or unable to carry out their duties (e.g. due to a conflict of interest), a designated Vice-Chair will act in the temporary capacity of the Chair.

Code of Ethics

The set of guidelines that outlines the expected behaviour that each CSI designation and fellowship holder has agreed to follow.

Complainant

Any entity (e.g. individual, partnership, corporation, organization) who reports an alleged Code of Ethics breach by a designation or fellowship applicant or holder.

Designation Ethics Committee (DEC)

A committee appointed by CSI and its Advisory Councils that determine appropriate outcomes for complaints, self-declarations, and other findings involving alleged breaches of the Code of Ethics by CSI designation or fellowship applicants or holders. 

Ethics Review Coordinator (ERC)

A CSI staff member appointed to collect and communicate all information related to an alleged breach of the Code of Ethics with the appropriate stakeholders.

Holder

An individual who possesses a CSI designation or fellowship.

1. Complaint Process

A suspected violation of the Code of Ethics by an applicant holder can be brought to CSI’s attention by:

1. an external party (e.g. client, colleague, employer, member of the public, regulator);
2. an applicant or holder; or
3. any other communication/information avenues (e.g., regulator reports, disciplinary actions published by other designation bodies, social network sites, newspapers)

1.1 Allegation is Brought to CSI’s Attention by an External Party

An individual filing an allegation is required to complete the “submit a complaint” form on the CSI website at https://framework-compass.live/en/credentials/complaints%3C/p%3E

The complaint must:

• identify the applicant or holder who has allegedly breached the Code of Ethics;
• identify the section(s) of the Code of Ethics that the applicant or holder allegedly breached;
• include all known relevant details of the allegation; and
• provide any supporting documentation

Upon receiving a complaint, the Ethics Review Coordinator (ERC) conducts an initial review to determine its relevance to the Code of Ethics and refers the complaint to the Chair of the Designation Ethics Committee (DEC) to evaluate whether the complaint involves a potential breach of the Code of Ethics.  The Chair of the DEC can decide that:

• the complaint does not involve a potential breach of the Code of Ethics, and that the ERC should advise the complainant of the decision, including any reasons why the complaint will not be escalated to the DEC.
• more information is required, and that the ERC should gather the additional information the Chair of the DEC requires so they can determine if the complaint involves a potential breach of the Code of Ethics.
• the complaint does involve a potential breach of the Code of Ethics, and that the ERC should commence a comprehensive investigation and include the case on the agenda for the relevant DEC meeting

At that time, the ERC will:

• inform the complainant that the complaint will be presented to the DEC for assessment.
• collect any information and/or evidence regarding the alleged violation (available from the complainant or through other communication/information avenues).
• inform the holder of the complaint, including the name of the complainant, the details of the complaint,, the sections of the Code of Ethics that were allegedly breached, the deadline of no less than fourteen (14) days by which the holder (or their representative) must submit a written response to the ERC, and that if no response is received from the holder (or their representative), the case will be reviewed at the next scheduled DEC meeting without their input.
• prepare and distribute a written summary of the case that includes all related information to the DEC so they can review the material in advance of their meeting.

1.2 Allegation Brought to CSI’s Attention by Applicants or Holders at the Time of Application or Annual Renewal

Applicants and holders are required to answer five “Fit and Proper” questions when applying for and annually renewing a designation or fellowship. If an applicant or holder answers yes to any of these questions, their application is forwarded to the Ethics Review Coordinator (ERC) for review.

CSI will not process a designation or fellowship application or renewal that contains a “Yes” answer to a “Fit and Proper” question until it has been reviewed by the ERC, the Chair of the Designation Ethics Committee, and if necessary, the Designation Ethics Committee (DEC).

Upon receiving an application where a “Fit and Proper” question has been answered “Yes”, the ERC contacts the applicant or holder to request that they provide their account of the events, including any mitigating circumstances that may have led to the event or occurred since the incident. Applicants or holders are required to respond and submit all pertinent documentation related to the event within ten (10) days of receiving the ERC’s original notification. Failure to provide a response or information requested by the ERC will result in the application being denied and may result in further sanctions.

Upon receiving all necessary information, the ERC presents the information to the Chair of the DEC, who evaluates whether the case should be referred to the DEC.  The Chair of the DEC can decide that:

• the case does not need to be reviewed by the DEC and that the ERC should advise the applicant or holder that their application or renewal will proceed without further delay.
• more information is required and that the ERC should gather the additional information that the Chair of the DEC requires so they can determine whether the case should be referred to the DEC.
• the ERC should prepare and distribute a written summary of the case that includes all related information to the DEC so they can review the material in advance of their meeting.

Where the case involves an on-going external regulatory, legal, or disciplinary process, the DEC may delay consideration of the matter until the proceedings are concluded. Depending on the nature of the allegation, the DEC will decide whether the holder’s designation or fellowship will continue to be held in good standing or temporarily suspended. The holder is required to provide updates for an on-going case to the ERC within 10 days of their occurrence.

For cases where the alleged breach of the Code of Ethics may result in the deferral/ban of an applicant’s designation or fellowship, or the suspension/revocation of a holder’s designation or fellowship, the Chair of the DEC may request that the applicant or holder attend a DEC meeting (via video conference) to present their case and answer questions posed by the DEC.

1.3 Allegation Comes to the Attention of CSI Through other Communication Means

CSI may become aware of potential breaches of the Code of Ethics by applicants or holders through other means, including but not limited to reports from self-regulatory organizations, securities commissions, other designation granting organizations, and information shared through social or regular media avenues.

When CSI becomes aware of the situation, the same steps in Section 1.2 will be followed.

1.4 Case Review and Decision

Once a case is referred by the Ethics Review Coordinator (ERC) to the Chair of the Designation Ethics Committee (DEC), the Chair considers any alleged breaches of the Code of Ethics and determines if the case should be referred to the DEC for review. The DEC reviews the case and determines whether the Code of Ethics has been breached and what, if any, action should be taken. Actions can include a formal reminder to follow the Code of Ethics, a warning letter, additional training, deferral/ban of an applicant’s application, suspension/revocation of a  holder’s designation or fellowship, or any other sanction that the DEC considers suitable to address the breach. Applicants and holders are required to abide by the findings of the DEC; however, they have the right to appeal the decision.

In the case of a public complaint, the Complainant will be advised of the decision once appeal options have been exhausted.

CSI retains the ultimate discretion and authority to temporarily and/or permanently ban or revoke any of its credentials from an individual. This prerogative may be exercised in cases involving actions by an applicant or holder that, while not directly violating the Code of Ethics, poses risk of, or resulted in, material damage or significant harm to the public, the financial services industry, the credential, or CSI. All such sanctions will adhere to the standard review process of the DEC and will be eligible for an appeal process. 

2. Confidentiality

All information collected, investigations, and proceedings are confidential. Any member of the Designation Ethics Committee (DEC), Appeal Committee, or members of CSI staff who are engaged in the Ethical Misconduct Process are bound by confidentiality agreements that prohibit them from discussing committee activities outside of the process. Exceptions may only be made where required by law or where, in CSI’s view, it is necessary to conduct the process publicly.

3. Designation Ethics Committee (DEC)

The Designation Ethics Committee (DEC) has been established to ensure all complaints and allegations are heard promptly and fairly.

3.1 Composition of the Designation Ethics Committee (DEC)

The Designation Ethics Committee (DEC) is comprised of up to 20 members who hold a CSI designation, and/or are appointed by a CSI Advisory Council.

One staff representative from CSI fulfills the role of the Ethics Review Coordinator (ERC) and provides administrative support, but is not a voting member of the DEC.

The DEC members appoint a Chair and a Vice-Chair who is approved by CSI.

All members of the DEC are volunteers, and their names are not published or otherwise made available in order to protect their privacy.

3.2 Conflict of Interest

Any individual involved with the ethical misconduct process that has a conflict of interest in relation to a particular complaint or case (e.g., has a direct personal or employment related connection to the holder or a personal or employment-related interest in the outcome of a hearing) shall be excluded from participating in the discussion and decision on that specific case.

3.3 Meeting Schedule & Structure

The Designation Ethics Committee (DEC) convenes monthly, typically via secure video conference.

A minimum of three panel members are required to vote on a case for it to be adjudicated and reviewed for that month. In the event of a tie, the Chair is authorized to cast a deciding vote.  

During a DEC meeting, the Ethics Review Coordinator (ERC) presents each case to the DEC with a summary and any supporting documentation collected as part of the investigation. If the applicant or holder is asked to participate in the meeting, they will be asked to present their case and answer any questions that the DEC may ask them.

Once the case is presented, the DEC examines the evidence to determine if there were any breaches of the Code of Ethics and any resulting sanctions that will be imposed.

All meeting documents are confidential and are not made available to the applicant, holder, or the public.

3.4 Meeting Outcomes

After reviewing and deliberating the case, the Designation Ethics Committee (DEC) can:

• dismiss the case if there is no evidence of a breach of the Code of Ethics; or
• impose sanctions if there is evidence of a breach of the Code of Ethics.

Sanctions may include, but are not limited to a:

• reminder to adhere to the Code of Ethics
• written warning to adhere to the Code of Ethics
• requirement for the applicant or holder to complete supplementary course(s).
• deferral of the applicant’s request for designation or fellowship
  • for a specified period;
  • indefinitely, specifying conditions for reinstatement; or
  • permanently
• suspension of the holder’s designation or fellowship
  • for a specified period;
  • indefinitely, specifying conditions for reinstatement; or
  • permanently

If a designation is suspended the holder will be required to discontinue use of the designation and remove any references to holding the designation from any and all materials and will return current letters of certification to CSI. All suspensions are publicized on the CSI website.

All case outcomes will be recorded in the applicant’s or holder’s CSI records.

CSI has the right to share information about case outcomes, including sanctions, with regulatory bodies, other designation granting organizations, and the applicant’s or holder’s employer.

Examples of penalties are provided for reference. However, note that sanctions can vary depending on the situation. These examples are for illustrative purposes only and do not guarantee that sanctions will be the same if similar situations occur.

3.5 Designation Ethics Committee Decision Notification

The Ethics Review Coordinator (ERC) notifies the applicant or holder in writing within fifteen (15) days of the Designation Ethics Committee (DEC) rendering its decision. The notification includes the decision of the DEC, a summary of the reasons for the decision, and any sanctions imposed. The notification is signed by the ERC on behalf of the DEC, is sent by email with a secure password, and is kept on file indefinitely at CSI.

4. Appeals of Decisions of the Designation Ethics Committee

A designation or fellowship applicant or holder has the right to appeal the decision of the Designation Ethics Committee (DEC).

All appellants are required to cooperate with CSI and abide by the Appeal Process. Failure to do so may result in additional breaches of the Code of Ethics and/or dismissal of the appeal.

Typically, sanctions imposed by the DEC do not commence until the Appeal Panel renders a decision. However, in circumstances where the protection of the public is at stake, sanctions may be applied immediately and kept in force until the Appeal Panel has rendered its decision.

4.1 Grounds for Appeal & Request Submission

An applicant or holder may appeal on the grounds that the Designation Ethics Committee (DEC):

• made a significant and material error regarding its interpretation of the Code of Ethics,
• made a significant and material misapprehension of the facts, and/or
• imposed a penalty that is manifestly unreasonable considering the proven facts.

The appellant must provide a written submission for the Appeal Panel’s consideration that explains their grounds and rationale for the appeal, as well as any recommended outcome(s) they are requesting.

A request for an appeal must be sent in writing to the Ethics Review Coordinator (ERC) within fifteen (15) days from when the DEC decision notice was sent to the applicant or holder. The ERC ensures that the appeal request includes all necessary information to proceed with the appeal. If the request for appeal does not contain the required information, the ERC will request the additional information from the appellant. If the required information is not provided within ten (10) days of the ERC’s request, the appeal will be denied.

If the appeal request is accepted, the ERC will set up an Appeals Panel and hire an external legal counsel to chair the Appeal Hearing. The ERC will inform the appellant of the Appeal Hearing date and require any supporting documents to be submitted at least fourteen (14) days before the hearing.  If the appellant does not provide supporting documents before the deadline, the ERC and the Appeal Panel Chair will decide whether to deny the appeal or proceed with only the information already supplied by the appellant.  

4.2 Fees and Costs of the Appeal

To appeal a decision of the Designation Ethics Committee (DEC), a non-refundable fee of $200 plus applicable taxes must be paid. This fee goes towards the cost of securing an independent legal representative to chair the Appeal Hearing. This fee must be paid within ten (10) days of receiving notification from the ERC that the appeal can proceed and the fee is payable. Failure to pay the fee on time will result in the appeal being denied.

Each party is responsible for covering their own costs, including any legal fees or other related expenses. Neither CSI nor any appellant is entitled to claim costs from the other or any other parties of the appeal (e.g. members of the DEC or Appeal Panel, the Chair of the DEC or the Appeal Panel, Ethics Review Coordinator (ERC), or any appeal participant) regardless of the outcome.

The ERC will deliver copies of all documents to be considered at the hearing, including documents reviewed by the DEC in making the original decision and any new documents provided by the appellant in support of the appeal, no later seven (7) days before the Appeal Hearing date.

4.3. Appeal Panel

The Panel is convened solely upon a formal request for an appeal.

4.3.1 Composition of the Appeal Panel

The Chair of the Appeal Panel will be an independent legal counsel with relevant experience in the carrying out of such hearings. The Chair will have no personal or business interest in the outcome of the decision. The Ethics Review Coordinator (ERC) will carry out the administrative functions for the Appeal Panel.

Members of the Appeal Panel are determined by CSI. Each panel shall consist of between three and five members who may have one or more of the following qualifications:

• hold the same designation as the appellant;
• be senior representatives of a relevant regulatory body or financial institution; and/or
• be members of a CSI Designation or Fellowship Advisory Council

No member of the Designation Ethics Committee (DEC) that was present for the prior hearing concerning a given matter may sit on an Appeal Panel.

4.3.2 Appeal Panel Functions

A minimum of three of the Panel members, the Panel Chair, and the Ethics Review Coordinator (ERC) must be present to hear any appeal. Each Panel member votes on an appeal decision and the decision is based on a majority vote of the present members. The Chairperson can provide counsel, but only votes in the event that the members’ vote results in a tie. The ERC does not vote.

4.4 The Appeal Hearing

The proceedings of the Appeals Committee are typically conducted via secure video conference.

The only individuals who can participate in the Appeal Hearing include the Appeal Panel Chair, the Appeal Panel members, the Designation Ethics Committee (DEC) representative, the appellant and their representative (if any), any required witnesses, and the Ethics Review Coordinator (ERC). All proceedings are confidential.

At the start of the Appeal Hearing, the Appeal Panel Chair welcomes all participants and explains the process that will be followed during the Appeal hearing.

The DEC representative presents the DEC’s decision and the basis upon which the DEC formed its decision and determined any sanctions.

The appellant or their representative presents the grounds for their appeal, and then may call witnesses and/or ask questions to the DEC representative regarding the decision that is being appealed.

The DEC representative may then ask questions of the appellant and provide any closing thoughts about the case.

The appellant may then ask questions of the DEC representative and provide any closing thoughts about the case.

Panel members may pose questions to the DEC representative, the appellant, or their representative.

Once all relevant information has been presented and any witnesses heard to the extent the Appeal Panel requires, the Appeal Panel Chair and the Appeal Panel members will confer without the presence of the other participants. This segment of the hearing will not be formally transcribed.

4.5 Appeal Panel Decision

The Appeal Panel will determine if there was an error in the prior decision and will confirm, modify, or overturn the prior decision of the Designation Ethics Committee (DEC). The Appeal Panel may impose any additional penalties it deems appropriate.

All decisions of the Appeal Panel are provided in writing and prepared by the Appeal Panel Chair. The Appeal Panel’s decision and reasons for the decision are sent by the Appeal Panel Chair directly to the Ethics Review Coordinator (ERC) within fifteen (15) days of the Appeal Hearing. The ERC sends the appellant and the DEC representative a password protected copy of the Appeal Panel decision within five (5) days of receiving it from the Appeal Panel Chair. This letter of decision is kept on file with CSI indefinitely and a notice is attached to the appellant’s  CSI record.

The decision of the Appeal Panel shall take effect immediately unless otherwise indicated in the appeal decision. The decision is final and there no further appeals or reviews of the decision are available to any party.

5. Publication and Disclosure of Ethics Related Decisions

Notices of disciplinary action may be published on the CSI designation website. The publication will include the applicant’s or holder’s name, and additional information will be available to third parties upon request. While under suspension the holder’s name will not appear on the directory of holders in good standing.

6. Ongoing Monitoring

CSI will ensure sanctioned holders comply with decisions from the Designation Ethics Committee (DEC) or the Appeal Panel. Non-compliance will be addressed through further sanctions, legal channels, and reported to the applicant’s or holder’s employer and relevant regulators.

Unauthorized use of a CSI designation or fellowship will also be handled.

7. Reinstatement Following Suspension

An applicant or holder who has had their credential deferred or suspended may request to be reinstated on the deferral or suspension expiration date provided they:

1. file an application or renewal request for the designation or fellowship;
2. confirm that they have followed the original decision of the DEC or Appeal Panel;
3. agree to the current relevant Code of Ethics and Ethical Misconduct Review Process;
4. confirm that there have been no additional breaches of the Code of Ethics since the commencement of the deferral or suspension;
5. confirm that the continuing education or industry contribution requirements of the relevant designation or fellowship have been met;
6. pay the applicable application or renewal fee.