Group Newspapers plc
under Sections 432(2) and 442 of the Companies Act 1985
The Honourable Sir Roger John Laugharne Thomas
Raymond Thomas Turner FCA
appointed by the Secretary of State for Trade and Industry)
CHRONOLOGY OF SIGNIFICANT EVENTS
Reports on Pergamon Press Ltd. Robert Maxwell severely criticised
"…not… a person who can be relied on to exercise proper stewardship
of a publicly quoted company".
Maxwell's private companies re-acquired Pergamon Press Ltd.
Maxwell's private companies obtained a controlling interest
in British Printing Corporation; Robert Maxwell became chief
executive. Company subsequently renamed Maxwell Communication
Robert Maxwell's companies (private side) acquired Mirror
Group Newspapers (MGN) for £113m.
Maxwell ended restrictive labour practices at MGN and introduced
modern technology; MGN became highly profitable and was able
to provide over £300m to the private side between 1984 and
and the private side's period of expansion; a number of companies
of substantial worth and potential acquired.
funds commenced lending monies to private side.
side incurred over £300m in borrowings taking up rights issue
borrowed $3 billion and acquired Macmillan and Official
Pension funds commenced lending shares to provide collateral
for bank loans to private side.
side bank borrowing approached £1 billion. Robert Maxwell
began selling assets but also continued acquiring companies.
Maxwell spent £130m (some through offshore entities) on
Maxwell's companies faced a financial crisis in late summer
as MCC had to repay part of $3 billion borrowings.
made to float 49 per cent. of MGN.
companies only survived 31 December year end through borrowings
from pension funds and unauthorised overdrafts; bank borrowings
remained at about £1 billion.
Advisers worked on the flotation.
Robert Maxwell spent £105m (some through offshore entities)
on MCC shares.
MGN floated - produced £210m to reduce MGN bank borrowing.
At the time private side owed pension funds £100m and was
using £270m of their assets as collateral; private side
bank borrowings remained at about £1 billion.
to July: Robert Maxwell spent £72m through offshore entities
on MCC shares and £26m on MGN shares.
to November: MGN supported private side through provision
of cash and use of its bank borrowings.
Robert Maxwell died. Empire thereafter collapsed and MGN
sought support of bankers.
In June 1992 we were appointed by the Secretary of State for Trade
and Industry as Inspectors to investigate the affairs of Mirror
Group Newspapers plc.
- we had
completed most of our enquiries into the complex events.
- we provided
to the Secretary of State an Information Memorandum in two volumes
setting out a detailed account of the information we had then
- we would
have been able to complete our Report that year if it had not
been for the criminal proceedings arising out of the collapse
of the company empire controlled by the late Mr Robert Maxwell.
- we submitted
to the Secretary of State some recommendations.
criminal proceedings and problems surrounding and following from
them thereafter substantially delayed the completion of our enquiry.
As requested on our appointment, the focus of our Report is on
the flotation of Mirror Group Newspapers on 30 April 1991. We
have sought to explain:
- why Mirror
Group Newspapers was floated by Mr Robert Maxwell;
- what the
due diligence procedures carried out did not reveal, particularly
about the pension funds and why the abuse of the pension funds
was not discovered earlier;
- what was
not done at the flotation, but ought to have been;
- why within
seven months of April 1991 the support of Mirror Group Newspapers
bankers was necessary.
do this we have had to describe some earlier events at Mirror
Group Newspapers and its pension funds and, as Mr Robert Maxwell
ran his financial empire (including the pension funds) as one,
some of the events elsewhere in the empire until his death in
November 1991. The Report must not, however, be seen as an account
of all Mr Robert Maxwell's activities at MGN or elsewhere, or
of all the circumstances surrounding the collapse of his empire
and the aftermath.
the outset of our Report, we provide below a brief summary of
the events, the responsibility for what happened and our main
recommendations and lessons from the events.
1971 DTI Report
In 1971 Inspectors appointed by the DTI produced a Report on Pergamon
Press Ltd which was severely critical of Mr Robert Maxwell. They
having to conclude that, notwithstanding Mr Maxwell's acknowledged
abilities and energy, he is not in our opinion a person who
can be relied on to exercise proper stewardship of a publicly
two subsequent Reports on Pergamon Press Ltd and related companies
in 1972/73 the same Inspectors detailed and criticised Mr Robert
Maxwell's business methods.
rebuilding of Mr Robert Maxwell's fortunes and his acquisition
of Mirror Group Newspapers
After the events that had led to those Reports, Mr Robert Maxwell
spent his time rebuilding his businesses. The two most significant
- He re-acquired
in 1974 Pergamon Press Ltd and its scientific journal publishing
business which he made highly profitable.
- He obtained
in 1980 a controlling interest in British Printing Corporation
plc which was on the brink of insolvency. It was a listed company,
but, despite the views expressed in 1971, he became its chief
executive and subsequently its chairman. He restored the company
to profitability and re-established himself in the eyes of many
bankers and ensured their support for future expansion. This
company was renamed by him Maxwell Communication Corporation
placed the ultimate ownership of these companies in the Maxwell
Foundation, a Liechtenstein entity that he secretly controlled
though a Swiss lawyer; this was characteristic of the "need to
know" basis on which he ran his businesses. He was the only person
in a position to have a full picture of all his interests.
On 12 July 1984 Mr Robert Maxwell's private companies (known as
the "private side") acquired Mirror Group Newspapers from Reed
International plc for £113m. At the time of the purchase Mr Robert
Maxwell undertook to make a partial flotation of the Company.
He assumed complete control over its management and finances and
gradually restored Mirror Group Newspapers to profitability by
ending restrictive labour practices and introducing modern technology.
period of expansion
Both Mirror Group Newspapers and Pergamon Press' scientific journals
business had strong cash flow. Over £300m of the cash generated
by Mirror Group Newspapers was, by December 1990, transferred
by Mr Robert Maxwell and used to finance other businesses. The
scientific journals business was transferred from the private
side to Maxwell Communication Corporation in early 1986. On the
strength of those sources of cash, Mr Robert Maxwell announced
in April 1986 his intention of achieving through Maxwell Communication
Corporation a global communications and information company with
revenues of £3-£5 billion by the end of the 1980s; he saw himself
competing with Mr Rupert Murdoch and his News Group Newspapers.
Mr Robert Maxwell began a frenetic period of corporate expansion
in the UK, Europe and North America and acquired companies of
substantial worth and potential. On 1 July 1986 Maxwell Communication
Corporation became a FTSE 100 company.
In the course of this expansion, Mr Robert Maxwell was courted
by many leading professional advisers and investment banks who
were eager to lend money to him or advise on corporate acquisitions
which provided them with significant fees. He entertained and
was entertained by leading politicians and world statesmen. The
fact that leading professional advisers and banks were prepared
to act for him or do business with him was used by him further
to re-establish his reputation. It was during this period that
Mr Robert Maxwell's youngest son, Mr Kevin Maxwell, became an
important member of the management of his businesses.
Robert Maxwell's management of the companies and his use of the
pension funds from 1985
During this period of expansion significant practices developed
in relation to Mr Robert Maxwell's companies and the pension funds:
- Mr Robert
Maxwell dominated the management of all these companies. He
gradually took over the management of a substantial part of
the investments of their pension funds, save for those governed
by US legislation.
- Mr Robert
Maxwell personally controlled through a central treasury the
movement of cash within and between his companies (including
having sole signatory authority for an unlimited amount over
the bank accounts including those of his main listed company
Maxwell Communication Corporation).
- Cash was
borrowed by the private side on a regular and unsecured basis
from the pension funds beginning in 1985. This did not become
known to the trustees of the funds. The accounts were "window
dressed" with balances brought to nil at the financial year
end to avoid disclosure.
- The pension
funds were used on a regular basis to assist in the corporate
strategy of the empire and to provide cash in exchange for investments
which Maxwell Communication Corporation or other businesses
needed to sell.
- The pension
funds made substantial investments in Maxwell Communication
- The presentation
of the financial position of Mr Robert Maxwell's companies and
the pension funds in the annual accounts was carefully managed
and the minimum disclosure made.
- An in-house
nominee company, Bishopsgate Investment Trust plc, was established
to hold some of the assets of the public companies and private
side as well as the pension funds; there were delays in recording
the beneficial ownership. This meant that some of those dealing
with Mr Robert Maxwell did not necessarily know who in fact
owned the shares and the similarity in names of the various
"Bishopsgate" companies caused confusion.
practices were known to Mr Kevin Maxwell and those close to Mr
Robert Maxwell in the management of his companies as well as to
Coopers & Lybrand Deloitte. Coopers & Lybrand Deloitte were the
auditors of the public companies and private side companies and
pension funds and provided advisory services to Mr Robert Maxwell
in connection with the acquisition and disposal of companies.
Although during the period of expansion some of the pension funds
benefited from Mr Robert Maxwell's investment skill and the extra
income derived from lending to the private side, even during this
period there were losses.
- When Mirror
Group Newspapers needed £34m cash in 1986, this was provided
by the pension funds in return for shares held by Mirror Group
Newspapers in Reuters. When these shares were transferred back
in 1989, the pension funds not only made a loss on the transaction,
but never obtained any part of the significant profits which
the private side earned when the Reuters' share price increased
very shortly thereafter.
- The pension
funds were used to purchase Maxwell House in Holborn, London
in 1986, but it was the private side that obtained the real
benefits on the transaction.
In 1988, two investment management companies controlled by Mr
Robert Maxwell, Bishopsgate Investment Management Ltd (BIM) and
London and Bishopsgate International Investment Management plc
(LBI), were authorised by IMRO, the regulator. Despite doubts
expressed as to whether Mr Robert Maxwell was "fit and proper",
it was considered that there was insufficient evidence against
him to deny approval. BIM and LBI managed a significant proportion
of the investments of the pension funds and LBI became the investment
managers of an investment trust, First Tokyo Index Trust plc.
Subsequent inspections by IMRO failed to uncover the use being
made of the pension funds.
developing financial pressures on Mr Robert Maxwell's companies
As a result of a rights issue by Maxwell Communication Corporation
in 1987 which was intended to finance acquisitions, the private
side assumed, in taking up the rights, a very substantial debt
burden of over £300m; the debt grew with further acquisitions
by the private side, including the acquisition of AGB Research
plc in October 1988 for £134m. All that borrowing was secured
on property or shares; most of the shares used as security were
shares in Maxwell Communication Corporation. By the beginning
of 1989 the bank borrowing of the private side approached £1 billion.
In addition, Maxwell Communication Corporation itself also made
very substantial borrowings of $3 billion to finance, in 1988,
the purchase of Macmillan Inc. and Official Airlines Guide Inc.
for which Mr Robert Maxwell overpaid.
As Mr Robert Maxwell had always regarded the pension funds as
his, when financial pressures on his companies became greater
in 1988, he made greater use of the pension funds through the
practices identified in paragraph 6. Some banks became reluctant
to accept Maxwell Communication Corporation shares as collateral
for loans to the private side, because they would in effect be
taking for a loan to one group of companies controlled by Mr Robert
Maxwell, collateral from another company controlled by him. From
November 1988, Mr Robert Maxwell therefore began to make use of
the more marketable blue chip shares held by the pension funds
and First Tokyo Index Trust as collateral for bank borrowings
to the private side; this was described as 'stocklending' to make
it appear to be the legitimate practice of lending securities
to market makers as part of ordinary share dealing activities.
Cash continued to be borrowed from the pension funds by the private
side without providing any collateral to the pension funds for
these loans. A significant part of the shares of the pension funds
and First Tokyo Index Trust which were used as collateral were
held by an independent custodian.
Mr Robert Maxwell ran his companies and the pension funds as if
they were one. He moved assets between them as best suited his
overall interests. However, the complex ownership and financial
structure of his empire and the concealment of the use of the
pension funds made it difficult for banks to gain a clear picture
of the financial strength of his empire. The practice was to be
"economic with the information" supplied to them. Although all
the groups of companies and pension funds within Mr Robert Maxwell's
empire were audited, they were not audited at a common date. Nor
was there any overview of the empire as a whole.
Although Mr Robert Maxwell began an asset disposal programme in
1989 to ease the financial pressures, he went on acquiring companies
and would not contemplate approaching the banks for re-negotiation
of the debt.
Robert Maxwell and Maxwell Communication Corporation shares
Mr Robert Maxwell was obsessed by the Maxwell Communication Corporation
share price; it was also important as it affected the amount of
collateral he had to provide when Maxwell Communication Corporation
shares were used to secure loans to the private side. Although,
as can be seen from the chart, he always held more than 50 per
cent. of Maxwell Communication Corporation, he continued to buy
Maxwell Communication Corporation shares to be held by his private
companies and the pension funds. From May 1989 he manipulated
the market, principally by buying shares secretly through overseas
investment bank with whom he principally dealt was Goldman Sachs.
The extent of Mr Robert Maxwell's activity was known to Mr Kevin
Maxwell and some of those closely associated with Mr Robert Maxwell.
However, the true extent of these activities was unknown to the
regulatory authorities in the UK or the USA. The expenditure on
Maxwell Communication Corporation shares contributed to the declining
financial condition of the private side.
financial crisis in the summer of 1990
By the summer of 1990, in a less favourable economic climate,
Mr Robert Maxwell's private companies and Maxwell Communication
Corporation faced a substantial financial crisis as part of Maxwell
Communication Corporation's debt was scheduled to be repaid in
the autumn and the prices which could be obtained for businesses
owned by Maxwell Communication Corporation were not as high as
had been hoped. £100m was borrowed by the private side from the
pension funds in May and June 1990, much of which was provided
from the sale of pension fund investments. To provide cash for
Maxwell Communication Corporation, two Canadian assets owned by
Maxwell Communication Corporation were transferred to Mirror Group
Newspapers in October 1990 for £129m which Mirror Group Newspapers
financed by borrowing. Maxwell Communication Corporation's share
price also came under pressure; significant purchases of Maxwell
Communication Corporation shares were made by Mr Robert Maxwell;
during 1990 he spent £130m on these. Two of the purchases from
Goldman Sachs in 1990 were announced as "options".
The private side was able to survive the financial year ended
31 December 1990 only through a carefully planned series of transactions
involving the use of pension fund assets and unauthorised overdrafts
obtained by LBI from Morgan Stanley Trust Company of $135m (£74m)
and Lloyds Bank plc of £52m. $56m (£31m) of the overdraft from
Morgan Stanley Trust Company was on a pension fund account.
The financial crisis of 1990 was the catalyst for the decision
to float Mirror Group Newspapers on the Stock Exchange in London
by selling 49 per cent. of the shares. This was intended not only
to raise money to reduce the overall bank borrowings but to provide
Mr Robert Maxwell with shares in a second listed company for use
as further collateral for bank borrowings.
It was initially hoped that the price obtained on the flotation,
together with the sale of other assets, might significantly alleviate
the financial crisis faced by Mr Robert Maxwell's empire. However
it became clear that the proceeds which would be obtained from
the sale of 49 per cent. of Mirror Group Newspapers would not
compensate the private side for the loss of its use of Mirror
Group Newspapers' cash flow; the sale by Maxwell Communication
Corporation of the scientific journals business to Elsevier in
April 1991 ended that source of cash flow to Maxwell Communication
Corporation. It is apparent therefore that Mr Robert Maxwell knew
that, when Mirror Group Newspapers was floated, he had to go on
using the cash and other resources of Mirror Group Newspapers
and its pension funds after the flotation to support his empire
as had been done in the past.
Mr Robert Maxwell spent a further £105m on the purchase of Maxwell
Communication Corporation shares between January and April 1991,
largely through a third "option" and the use of overseas entities.
As can be seen from the chart, the Maxwell Communication Corporation
share price rose and this was thought to be helpful to the flotation.
Most of the purchases were from Goldman Sachs. By the 30 April
1991, the disclosed holding of Mr Robert Maxwell, his family,
the private side and the Maxwell Foundation in Maxwell Communication
Corporation was 68 per cent.; through the secret purchases by
other entities he controlled a further 8 per cent. bringing his
total holding to 76 per cent.
flotation of Mirror Group Newspapers on 30 April 1991
Mr Robert Maxwell appointed advisers of the highest reputation
to act for Mirror Group Newspapers for the purposes of the flotation
- Samuel Montagu & Co Limited, Smith New Court plc, Coopers &
Lybrand Deloitte, Clifford Chance, and Salomon Brothers International
Limited (who were appointed to market the issue in the USA and
Continent). Linklaters & Paines were appointed solicitors to the
issue. The advisers were paid a total of £9m in fees. The flotation
in London was accompanied by extensive marketing in the USA and
on the Continent.
On the flotation of Mirror Group Newspapers on 30 April 1991,
Mirror Group Newspapers had a modernised and profitable newspaper
business. The nature and extent of Mr Robert Maxwell's interest
in Mirror Group Newspapers, after a reorganisation of the ownership
structure, was properly disclosed. However, we have not discovered
any evidence that Mr Robert Maxwell had "changed his spots" as
regards his stewardship of a publicly listed company:
- No proper
consideration was given to the way Mr Robert Maxwell had run
Mirror Group Newspapers nor to the financial controls in place
at the time.
- No proper
system of corporate governance was put in place although two
distinguished non?executive directors were appointed to the
board of Mirror Group Newspapers. Mr Robert Maxwell was permitted
to be executive chairman.
- No change
was made to the financial controls. Mr Robert Maxwell had sole
signatory authority over the bank accounts for an unlimited
amount, the central treasury remained in control and on 29 and
30 April 1991 (the day before and the day of the publication
of the prospectus), £30m was paid from Mirror Group Newspapers'
funds for the benefit of Maxwell Communication Corporation and
the private side.
- The abuses
of the pension funds were neither discovered nor brought to
30 April 1991 cash loans from the pension funds amounted
to £100m and shares to the value of £270m were being used
as collateral for bank borrowings.
similar use being made of the shares in the portfolio of
First Tokyo Index Trust was discovered by the independent
directors on its board, but Mr Robert Maxwell offered to
purchase First Tokyo Index Trust on 30 April 1991 to prevent
that use being made public.
size of the pension funds' holding in Maxwell Communication
Corporation shares (which should have been disclosed in
a circular issued by Maxwell Communication Corporation in
October 1990) was reduced by a sale for £55m to two overseas
entities controlled by Mr Robert Maxwell on 25 April 1991;
that amount was never paid to the pension funds. The sale
was effected through Goldman Sachs as an agency sale in
New York; it did not come to the attention of the market
- The limited
financial review of the private side undertaken by Coopers &
Lybrand Deloitte at the time of the flotation did not take into
account the borrowing of cash from the pension funds or the
use of their shares as collateral for bank borrowings. The review
did not reveal the serious financial position of the private
side. Although Mirror Group Newspapers was meant to be a stand
alone company, its fortunes were inextricably linked to those
of the private side whose bank borrowings remained at about
For these principal reasons, Mirror Group Newspapers was not suitable
for listing and the prospectus was materially inaccurate and misleading.
use made of Mirror Group Newspapers' assets after flotation
Mr Robert Maxwell remained, after the flotation, in a position
to continue, as he had intended, to use Mirror Group Newspapers'
cash flow and to use its pension funds for the benefit of his
other businesses. Nothing in reality changed. There was no effective
The flotation raised £235m after payment of fees and commissions.
£210m was used to reduce the increased bank borrowing Mirror Group
Newspapers had undertaken when it had acquired the Canadian assets
from Maxwell Communication Corporation and £18m was paid to the
private side. However, the private side and Maxwell Communication
Corporation remained under severe financial pressure, despite
the continued disposal of other assets.
Mirror Group Newspapers and its pension funds continued to be
used therefore to support the other businesses. There were no
proper corporate or financial controls in place to prevent this.
Money was regularly borrowed and foreign exchange transactions
carried out to provide short term liquidity. In September and
October 1991, Mirror Group Newspapers borrowed a total of £80m
from banks so that it could be lent to the private side. Mirror
Group Newspapers also took a new lease of the Mirror Building
which was held by a private side company to enable that company
to refinance a loan.
purchase of Maxwell Communication Corporation and Mirror Group
Mr Robert Maxwell had agreed not to buy or sell Mirror Group Newspapers
shares at the time of flotation without the consent of Samuel
Montagu. When the share price declined he sought, but was refused,
permission to buy. He therefore used the same overseas entities
as he had used for the purchase of Maxwell Communication Corporation
shares to buy Mirror Group Newspapers shares to the value of £26m
from Goldman Sachs.
When in July and August 1991 the price of Maxwell Communication
Corporation shares was under pressure, Mr Robert Maxwell spent
a further £75m purchasing Maxwell Communication Corporation shares
through the overseas entities from Goldman Sachs in pursuit of
the same strategy. His total expenditure on the purchase of Maxwell
Communication Corporation and Mirror Group Newspapers shares in
1990 and 1991 was £344m. 27. By August 1991, the 51 per cent.
shareholding in Mirror Group Newspapers owned by the private side
and shares acquired secretly had been pledged to banks to secure
loans made to the private side.
collapse and the aftermath
By the end of October 1991, the private side, having made significant
disposals, had no substantial assets other than shares in Mirror
Group Newspapers and Maxwell Communication Corporation and property.
At that time the pressures became severe. For example, Goldman
Sachs required repayment of two loans. When repayment was not
made, they began selling Maxwell Communication Corporation shares
provided as collateral; the share price fell substantially. The
directors of Mirror Group Newspapers were examining the use being
made of about £40m of Mirror Group Newspapers' assets. Lehmans
demanded repayment of their financing. It is apparent that Mr
Robert Maxwell could not seek the support of his bankers to save
his empire without disclosing the true state of affairs and the
use he had made of the pension funds. The imminent collapse of
the empire was inevitable.
That collapse occurred shortly after Mr Robert Maxwell's death
on 5 November 1991. Mirror Group Newspapers also had to seek the
support of its bankers because of the use that had been made of
the assets of Mirror Group Newspapers and its pension funds.
As a result of the collapse, many pensioners suffered anxiety
and loss and the employees of Mr Robert Maxwell's companies suffered
uncertainty and redundancy. Mr Kevin Maxwell and others associated
with Mr Robert Maxwell faced a long criminal trial in which they
were acquitted. Disciplinary proceedings were brought by self
In view of the acquittals in the criminal proceedings, we decided
that we would proceed in a manner that did not, and would not
be seen to, call the acquittals into question. Nonetheless conduct
can be blameworthy without being criminal. Furthermore, because
our functions as Inspectors are essentially investigative so as
to ascertain and record facts and we are not a court of law, we
do not make legal determinations on any issue. Where therefore
we attribute responsibility, we do so in that context and in terms
primary responsibility rests with Mr Robert Maxwell. In addition
Mr Kevin Maxwell bears a heavy responsibility in respect of many
of the events. Some of those in Mr Robert Maxwell's management
team also bear a significant responsibility in respect of these
events. We have set this out in chapter 22.
practices in the pension funds which we have identified were known
to Coopers & Lybrand Deloitte. They and other professional advisers
and houses were closely involved with the directors of Mirror
Group Newspapers in preparing Mirror Group Newspapers for flotation;
all these bear to the extent we have ascribed in chapter 22 responsibilities
for the failure to make Mirror Group Newspapers suitable for listing
and the inaccuracies in the prospectus.
Sachs were the Investment bank with whom Mr Robert Maxwell principally
dealt when purchasing Maxwell Communication Corporation and Mirror
Group Newspapers shares and bear a substantial responsibility
in respect of the manipulation that occurred in the market.
was also a failure in three distinct areas of regulation:
of the pensioners
- the flotation
of new companies on the Stock Exchange
in shares in transnational markets.
recommendations and lessons from the events
we submitted some recommendations to the Secretary of State for
Trade and Industry in 1995, we have reviewed the position in the
light of the considerable developments that have occurred since
of the deficiencies in legislation and regulation which permitted
the events at Mirror Group Newspapers to occur have been rectified,
but there remain some important matters which still require to
be addressed or considered including:
on the work carried out by the Occupational Pensions Regulatory
Authority in providing more assistance to and encouraging training
for trustees who perform the vital role of the stewardship and
investment of Occupational Pension Schemes.
a statement of Guidance on the role and duties of advisers on
on the radical changes made by the Financial Services Authority,
in particular by imposition of severe sanctions against companies
who do not report fraud and by encouraging secondment of staff
from leading firms to regulatory bodies as a normal part of
a City career.
the regulation of markets in securities to provide more effective
control over firms that operate on a transnational basis to
ensure the fair, open and transparent conduct of such markets
and more effective investor protection.
more detailed guidance on the audit of business "empires".
the issues relating to auditor independence with a view to maintaining
public confidence in the audit and discouraging a firm which
provides audit services to a company from acting as reporting
accountants on that company.
non-executive directors more accountable, separating the offices
of chairman and chief executive, and providing extra statutory
Guidance on the duties of all directors to amplify the general
principles that it is proposed be incorporated into the Companies
an "expectations gap" by making the public aware that regulation
cannot entirely eliminate fraud, malpractice or manipulation
of the markets.
most important lesson from all the events is that high ethical
and professional standards must always be put before commercial
advantage. The reputation of the financial markets depends on