6.6.4

Factors relating to the nature of a contravention by an individual include:

(a) the nature of the FSMR or Rules contravened;
(b) the frequency of the contravention;
(c) the nature and extent of any financial crime facilitated, occasioned or otherwise attributable to the contravention;
(d) the scope for any potential financial crime to be facilitated, occasioned or otherwise occur as a result of the contravention;
(e) whether the individual failed to act with integrity or abused a position of trust;
(f) whether the individual committed a contravention of any professional code of conduct;
(g) whether the individual caused or encouraged other individuals to commit contraventions;
(h) whether the individual held a prominent position within the industry;
(i) whether the individual is an experienced industry professional;
(j) whether the individual held a senior position with the firm;
(k) the extent of the responsibility of the individual for the product or business areas affected by the contravention, and for the particular matter that was the subject of the contravention;
(l) whether the individual acted under duress; and
(m) whether the individual took any steps to comply with Regulatory rules, and the adequacy of those steps.