Ms Derville Rowland:

That is a legitimate question because this issue clearly has presented Davy, as detailed in the enforcement outcome, with a significant question to answer with respect to its own culture. The investigation uncovered a group of senior people who did not adhere to the serious obligations to manage conflicts of interest. That is a fundamental obligation in financial services, particularly where investors are served, some of whom will ultimately be consumers as well. In this case, there was a total disregard for any serious consideration of conflict of interest management. It seemed to be a conflict-free environment where no consideration was given, no minutes were taken, no oversight was exercised and they absolved themselves from any kind of adherence to the serious obligations. Even pre-approval for trading appeared to be given to others, even though the others had not been identified.

Moreover, there was an avoidance of the staff personal account dealing framework. A separate framework was in place in the firm that staff were meant to use for personal accounts that could have been overseen by compliance. The dealing happened on the firm account, which drove a coach and horses through the protection of having the separate deal framework, and that was absolved as well. The compliance function could not do its job because it was bypassed in that way.

There are serious questions for Davy to answer. The details of the public statement have given it that moment of reckoning that it clearly did not recognise it should have recognised.