Morgan Stanley Code of Ethics: 2008 vs. 2018
plus ça change…
By: Momena Haider
Introduction
Morgan Stanley – a leading investment bank and infamous villain in the Global Financial Crisis (GFC) of 2008 – updates its ‘Code of Ethics and Business Conduct’ regularly and has changed the document with additions and deletions since the GFC. A code of ethics is a set of rules and responsibilities businesses promise to adhere to, formulated by the businesses themselves. It has also been defined as “a formalized public statement that articulates the rules and regulations that will guide organizational practices with ethical consequences.”[1] Given a dark history including the GFC and the Great Depression of 1929 before that, businesses in the financial industry find value in presenting a code of ethics to outline expectations for employees and demonstrate integrity to the public. Morgan Stanley implements its code of ethics by attempting to promote a culture of ethical practice. However, since unethical behaviour has appeared since the GFC, the sufficiency of Morgan Stanley’s attempts at ethics remains questionable. This article examines the changes to Morgan Stanley’s code since the GFC by analyzing the reach and limits of a code of ethics, comparing Morgan Stanley’s April 2018 code to the June 2008 version, examining the implementation of the code, and judging its effectiveness.
Early Steps toward a Code of Ethics
The Great Depression was the impetus for the formation of Morgan Stanley in 1935. The Great Depression resulted from moral hazard – banks took risks with depositors’ funds. To prevent a recurrence of this crash, the Glass-Steagall Act of 1933 required U.S. banks to separate their investment banking and commercial banking businesses.[2] To conform with the new legislation, Henry S. Morgan and Harold Stanley of J.P. Morgan (alongside Dean G. Witter and Richard S. Reynolds, Jr.) spun off Morgan Stanley as an investment bank in 1935.[3]
Growth
With some of the most experienced leaders in the industry and close ties to J.P. Morgan, the company acquired a 24% market share among public offerings (equity shares owned by public investors) and private placements (equity shares owned by a select group of investors) in just its first year.[4] By 1938, Morgan Stanley was the top bond issuer out of all New York investment firms.[5] The company ventured into the securities business in 1941 as a partnership in order to join the New York Stock Exchange,[6] and over a decade later in 1954, it carried out the biggest securities issue of the time with General Motors.[7] By 1995, it ranked as the top mergers and acquisitions adviser worldwide.[8]
Crash
The U.S. government deregulated financial markets in the 1980s to increase competition, leading to the operation of commercial banks in the capital markets yet again. Greater deregulation followed in 2004 when then CEO of Goldman Sachs, Henry Paulson, lobbied the Securities and Exchange Commission (SEC). This deregulation meant a number of the largest investment banks including Morgan Stanley were exempt from the regulation limiting the amount of debt they could take on.[9] When John Mack became CEO of Morgan Stanley in 2005, he employed a more aggressive investment strategy and made the company a key player in the subprime mortgage business. The culture of excessive risk-taking fuelled by excessive compensation (itself propelled by competition from hedge funds) led to the abuse of the subprime mortgage business. Morgan Stanley alone issued or underwrote more than $227.5 billion in securities of subprime mortgages.[10] Between 2007 and 2008 when the housing bubble burst, Morgan Stanley lost 80% of its market value,[11] with one dollar in capital for every thirty-three it borrowed.
What is a Code of Ethics?
The Need
Alongside the lack of ethical roots of the behaviour leading to the GFC, directors are actually given dis-incentives to manage their fiduciary duties to non-investor stakeholders, e.g. employees, customers, and suppliers.[12][13] But it can be “seriously detrimental to long-run financial success and stakeholder value creation” when directors prioritize short-run profits, focusing on financial performance for large compensation packages.[14] Economic activity is reliant on voluntary stakeholders, so a better approach to long-run financial success would be through stakeholder value creation.[15] For instance, employees, customers, and suppliers respond positively when treated ethically; employees are committed,[16][17] customers are loyal,[18][19] and suppliers are more likely to maintain positive business relationships.[20][21] Both consequentialist and deontological ethics point banks toward enforcing an effective code of ethics and encouraging a moral culture.
Expectations
It is impractical to assume the purpose of a code of ethics is to solely prevent crises like the GFC, as codes existed prior to but were insufficient in themselves to prevent the GFC. Codes are one of many factors that prevent such crises and must be supported by external regulation and other social efforts that promote a culture of ethical practice. The ideal purpose of a code of ethics can be determined from the best application of a code of ethics, given the inherent limitations.
Limitations and Evaluating Effectiveness for Morgan Stanley
First, as a set of rules and responsibilities to which businesses promise to adhere to, the Code of Ethics is not evidence of a company’s integrity – as companies may present – but rather a commitment to perform with integrity. Since ethical consequences follow organizational decision-making, the Code of Ethics can be used as a guide to judge the integrity of the company’s directors and, in extension, the company. Evidence of Morgan Stanley’s integrity can be found solely in its actions as an organization. This may, or may not, be reflected in its long-term reputation, assuming unethical practice is reported at the same rate as the rest of the population and disclosed to its stakeholders.
Second, as a document formulated by the businesses themselves, Codes of Ethics are often used as self-regulatory tools rather than binding legal instruments. As a result, internal compliance reflects the effectiveness of the code. Morgan Stanley’s Code of Ethics forms part of the terms and conditions of employment for all officers and employees – not including directors – and has done so since before the GFC.[22][23]
Morgan Stanley’s Code of Ethics and Business Conduct Pre-2008 and Post- 2008
Structure
Both the June 2008 and April 2018 Code of Ethics begin with a section about what the code is – namely, a “statement of [Morgan Stanley’s] commitment to integrity and high ethical standards.”[24][25] The documents also disclaim the Code of Ethics cannot cover every legal or ethical issue a director or employee may face at the company in this section.
The final section of both versions is called ‘Your Personal Commitment.’ In this section, a distinction between the requirements of directors and the requirements of officers and employees is made. Officers and employees are required to acknowledge the separate 23-page Code of Conduct alongside the Code of Ethics.[26] Directors are instead required to acknowledge just the Code of Ethics which is reviewed here.
The 2018 version contains the following new/significantly revised sections on: Communications Protected by Law, Personal Lending and Borrowing, and Systems and Assets. This more recent version is subsequently about 500 words longer.
Description and Revisions
Consequences of Violating the Code of Ethics
The Code of Ethics forms part of the terms and conditions of employment for officers and employees, but not for directors. The “Consequences…” section begins by stating the role of the code in the terms and conditions of employment for officers and employees.
All directors, officers, and employees are “expected to cooperate in internal investigations of allegations of violations of the Code of Ethics…” In the 2018 version an affirmation of the personal responsibility of every individual at the firm is added:
“You are personally responsible for any improper or illegal acts you commit during your employment at or service to Morgan Stanley. You also can be held responsible for the action (or inaction) of others if you knew, or should have known, about their misconduct. Your activities may be reported to regulators and other governmental authorities, which could result in regulatory or criminal investigations. Depending on the outcome of those investigations, you may be subject to fines, permanent or partial suspension, disqualification from employment in the financial services industry and/or imprisonment.”[27]
In both versions, this section disclaims the code is not a contract guaranteeing employment or entitlement to any special privileges or benefits. There is also the exclusion of entitlement to rights in the 2018 version.[28][29]
Waivers and Amendments
Waivers are granted in exceptional circumstances by the Board of Directors – for whom the Code applies – and are promptly disclosed to shareholders. Amendments are also approved by the Board of Directors, and it is the responsibility of all employees to stay up to date with revised codes.[30][31] It is specified that material amendments must be approved by the Board of Directors in the 2018 version as the only revision.
Non-Retaliation Commitment
In both versions, the Non-Retaliation Commitment begins with a statement on the importance of open communication: “Our continued success depends on the open communication of concerns by all without fear of retaliation.”[32][33] It also states, “Morgan Stanley prohibits retaliation for reports or complaints that are made in good faith…”[34] Morgan Stanley’s commitment to take allegations of misconduct seriously and its commitment to prohibit the victimization of anyone raising a concern are additions in the 2018 version.[35]
Promoting a Safe and Healthy Work Environment
This section sets out Morgan Stanley’s commitment to environmental stewardship. In the 2008 version, a statement on Morgan Stanley’s commitment to compliance with environmental and workplace health and safety laws and regulations is made.[36] In the 2018 version, there is instead an assertion that Morgan Stanley takes its “environmental stewardship and responsible sourcing commitments seriously and continually seek[s] to improve the impact of our operations.”[37]
Treating Others with Dignity and Respect
This section deals with Morgan Stanley’s commitment to “a work environment in which all persons are treated with dignity and respect.”[38] The 2008 version states it is Morgan Stanley’s “policy to ensure equal employment opportunity without discrimination or harassment on the basis of race, color… or any other characteristic protected by the law.”[39] The 2018 version instead states Morgan Stanley’s policies “promote equal employment opportunity without discrimination or harassment.”[40]
The statement of Morgan Stanley’s expectation “that all relationships among persons in the workplace will be business-like and free of bias, harassment and violence”[41] is omitted in the 2018 version.
Conflicts of Interest
In both versions, directors’ responsibilities regarding potential conflicts of interest are laid out:
“Directors should disclose any actual or potential conflicts of interest to the Chairman of the Board and the Chief Legal Officer, who will determine the appropriate resolution. All directors must recuse themselves from any Board discussion or decision affecting their personal, business or professional interests.”[42]
In the 2008 version, supervisors’ responsibility “to manage conflicts they identify or that are escalated to them according to our policies and the procedures of their business unit” is emphasized within the Potential Business Conflicts subsection.[43] In the 2018 version, the focus is instead on the responsibility of officers and employees to take appropriate action and bring a potential conflict to the attention of the supervisor.[44]
In the Potential Personal Conflicts subsection, all employees – including directors – are told to avoid any investment, activity, or relationship that could impair their judgement or interfere with their responsibilities on behalf of Morgan Stanley. But because appearances matter, even the appearance of interference with Morgan Stanley related responsibilities must be avoided as well.[45] While the 2008 version stops at the appearance of interference with responsibilities, avoiding the appearance of impairment to judgement is added to the 2018 version.[46]
The list of potential personal conflicts is much shorter in the 2018 version, as there is some grouping. The differences and grouping are demonstrated in the table below.
In the 2008 version, officers and employees “must promptly report to their supervisor or [the Legal and Compliance Department (LCD)] any investment, activity, interest … that reasonably could be expected to give rise to a conflict of interest or appearance of a conflict.”[49] In the 2018 version, officers and employees are themselves responsible for reporting potential personal conflicts.[50] In addition to the LCD, the Conflicts Management Officer (CMO) and Global Conflicts Officer (GCO) are included as being able to take reports of potential personal conflicts in the 2018 version.[51]
Morgan Stanley’s Global Conflicts of Interest Policy is referred to for further information in both versions.
Gifts and Entertainment
Morgan Stanley does not prohibit the receiving of gifts and business entertainment in either version of the code.[52][53] However, in both versions the potential for legal concerns is raised. The Code of Conduct is also referred to for more information on the conditions under which gifts and entertainment may be received or provided. One of such conditions found in the 2018 Code of Conduct includes the requirement to be present with the client when business entertainment is received or provided such that the overall relationship is enhanced. A statement highlighting the utility of gifts and entertainment in fostering “goodwill in business relationships” is added in the 2018 version to reflect this.[54
Political Contributions
Officers and employees are required to follow set procedures with their LCD prior to engaging in any political activity, which is restricted.[55][56] In the 2018 version, the Political Contribution Tracking System is referred to for officers and employees to obtain approval/preclearance.[57] A sentence on personal responsibility to confirm all personal political activity is lawful is added in the 2018 version.[58]
Reporting Misconduct
Directions for reporting misconduct are set out in this section. This includes procedures for reporting the conduct of senior executives, directors, the Chief Legal Officer, and the Audit Director, as well as all other employees.[59]
In the 2018 version, the Integrity Hotline is included for reporting potential violations. There is also reference to the Global Speaking Up and Reporting Concerns Policy in the 2018 version, where those reporting potential violations can get more information on anonymity.[60]
Maintain Accurate Books and Records
Morgan Stanley’s requirement to maintain accurate books and records is stated in both versions.[61][62] The requirement to never make false or misleading entries is omitted in the 2018 version and is replaced by a reference to the firm’s full established policies and procedures which officers and employees must be familiar with in their business/function.[63]
Communications Protected by Law
The Protecting Confidential Information section previously did not include a subsection on communications with the public in the 2008 document, whereas the 2018 document contains a section labelled ‘Communications Protected by Law.’ Reporting obligations are covered in the 2008 policy’s two-paragraph section called ‘Be Honest and Fair in your Communications with the Public,’ presented as a company responsibility imposed onto the employee. This section exists independently in the 2018 document too, as ‘Communications with the Public.’ However, the addition of the Communications Protected by Law section to the 2018 document importantly shifts the responsibility for disclosure of information onto the employee – as a choice the employee can make independently of the company, so that the company’s reputation is not tarnished as a result of employee’s failure to report information.
Personal Lending and Borrowing
The following is the Personal Lending and Borrowing statement in the 2018 version:
“Your personal lending and borrowing activities must not result in legal, ethical or business conflicts or otherwise appear improper. You must not accept preferential treatment if the offer appears to be an attempt to obtain favorable treatment in dealings with Morgan Stanley. Morgan Stanley may extend credit to its directors, executive officers and principal shareholders in the ordinary course of business and on substantially the same terms prevailing at the time for comparable loans to third parties.”[64]
In the 2008 version, this section is not present and there is no mention of personal lending and borrowing.
Systems and Assets
In the 2008 version, there is a shared statement on protecting systems and assets:
“Our policies regulate use of our systems, including telephones, computer networks, e-mail, instant messaging and remote access capabilities. Generally, you should only use Morgan Stanley’s systems and property for Morgan Stanley business. Do not access systems or locations that are not reasonably related to your responsibilities, and report any suspected misuse or theft of our assets. Under no circumstances should you use our systems to send or store unlawful, discriminatory, harassing, defamatory or other inappropriate materials.”[65]
In the 2018 version, there are separate subsections on systems and assets under the section Protecting Our Interests, and a statement on individual responsibility to safeguard the assets of the firm, clients, suppliers, and business partners is added. The following is another addition regarding the protection of firm assets:
“Misappropriation, misrepresentation, including fraudulent financial reporting, or unauthorized disclosure of Firm assets is a breach of your duty and may constitute fraud against the Firm, even when such acts are committed without personal gain. Similarly, carelessness, waste or unauthorized use in regard to Firm assets is also a breach of your duty.”[66]
How is the Code Implemented?
Terms and Conditions
The code is firstly implemented via its role in the terms and conditions of employment.
Compliance Positions
The code is also implemented through the specialized roles for compliance within the company. For example, the Global Financial Crimes Compliance department “coordinates day-to-day implementation of the Firm’s enterprise-wide financial crime prevention efforts,”[67] with responsibility for the “governance, oversight and execution of the Firm’s Anti-Money Laundering (AML), Economic Sanctions, Anti-Corruption and Government and Political Activities Compliance programs.”[68]
Regulation
Since Morgan Stanley’s Code of Ethics includes many legal obligations, external regulation plays an important role in the implementation of the code. Banks in the U.S. have at least one federal supervisor, whether chartered at the state or federal level, to implement the Federal Reserve System’s regulation. For instance, Morgan Stanley will be required to adopt a cybersecurity program by March 1, 2019.[69]
Philanthropy
The ‘Giving Back’ page on Morgan Stanley’s website includes various programs the firm runs to demonstrate its commitment to the public, the most general stakeholder. For example, the Global Alliance for Children’s Health focuses on innovations in pediatric care and delivers it to underserved children, amongst other programs.[70] With employee engagement in volunteering alongside philanthropic programs, Morgan Stanley attempts to create an ethical culture to support and champion the Code of Ethics.[71]
Diversity and Inclusion Programs
Morgan Stanley implements programs to promote a culture of diversity and inclusion, as pointed to in the Treating Others with Dignity and Respect section of the Code of Ethics. The Forum for Women, Multicultural and LGBT Financial Advisors creates a community amongst the groups in the firm.[72] Other programs include Return to Work, Veterans at Morgan Stanley, Supplier Diversity, involvement in UK Women in Finance Charter, the Multicultural Innovation Lab, and Women in Banking Scholarships.
Changing Relationships
Another way the culture change is implemented is through the changing dynamics between senior executives representing and reflecting the company. While in the past Morgan Stanley’s internal culture has been described as a “savage cult,”[73] with a “military approach and killer attitude,”[74] now senior executives from wealth management, securities, and investment banking are at a position of mutual respect and collaboration.[75]
Legal and Ethical Issues Since 2008
Morgan Stanley’s ethical turmoil did not end after revisions to the Code of Ethics and attempts to build an ethical culture following the GFC. The following is a non-comprehensive list of some of the legal and ethical issues Morgan Stanley has faced since the GFC.
- 2008– Sued by a group of institutional investors for negligence in conveying ratings from agencies such as S&P and Moody’s.[76]
- 2012– Fined $1.75 million by the Financial Industry Regulation Authority (FINRA) for insufficient supervision of, and unreasonable bases for, recommending securities, plus a further $647,700 for using funds from municipal bond offerings to pay for lobbying.[77]
- 2012– Former real estate executive in China pleaded guilty to evading internal controls for bribery after receiving 35 notices and at least 32 compliance trainings.[78]
- 2012– Sued by the American Civil Liberties Union for racial discrimination in pushing African-American homeowners into subprime predatory loans.[79]
- 2014– Fined $4 million by FINRA, alongside fines to 9 other banks, for allowing their stock analysts to solicit business and offer favorable research coverage to win investment banking business with Toys R Us in 2010.[80]
- 2015– Sued by African-American former financial advisor Kathy Frazier for discrimination based on race, as well as for instituting a racially charged policy that prevents employees from addressing concerns of racism externally.[81]
- 2017– Agreed to pay a $13 million penalty for overbilling investment advisor clients due to failure to adopt and implement compliance policies, as well as for failure to comply with the annual custody examination requirements for two consecutive years.[82]
- 2018– Sued by African-American former wealth manager John Lockette for failing to reform discriminatory policies and practices.[83]
Conclusion
Apart from the new section called Personal Lending and Borrowing in the 2018 Code of Ethics and reference to new external policies/sources for further guidance, additions and alterations of the code primarily shift the focus to personal responsibility. This creates a legal distance between the activities of the individuals that make up the firm from the firm itself as an entity, allowing the firm to discipline and/or fire those revealed to act in disregard of the code while maintaining its activities.
There is a need for a code of ethics so fiduciary duties toward non-investor stakeholders are managed, and Morgan Stanley’s code does in fact address its responsibilities to clients, suppliers, and business partners. External regulation and other social efforts that promote a culture of ethical practice complement codes of ethics, and there is evidence Morgan Stanley has employed strategies to attempt a change in culture to ensure compliance with the code. However, the effectiveness of compliance is brought into question by persisting legal and ethical issues. It must be noted these issues are mostly exposed through regulatory bodies and whistle-blowers, while unethical behavior day-to-day may go unreported outside the company due to self-regulation limitations.
Editor: Eric Witmer
Notes
[1]Parboteeah, Praveen, and John B. Cullen. Business Ethics. Routledge, 2013, chap. 10.
[2]“Morgan Stanley – Overview, History of Global Investment Bank.” Corporate Finance Institute, www.corporatefinanceinstitute.com/resources/careers/companies/morgan-stanley-investment-bank/, para. 8.
[3]Chernow, Ron. The House of Morgan: an American Banking Dynasty and the Rise of Modern Finance. Grove Press, 2010, p. 12.
[4]“Morgan Stanley – Overview, History of Global Investment Bank.” Corporate Finance Institute, www.corporatefinanceinstitute.com/resources/careers/companies/morgan-stanley-investment-bank/, para. 9.
[9]Patterson, Scott. The Quants: How a New Breed of Math Whizzes Conquered Wall Street and Nearly Destroyed It. Crown Business, 2009, p. 201.
[10]“Morgan Stanley.” Spirit of America – SourceWatch, www.sourcewatch.org/index.php/Morgan_Stanley#cite_ref-4
[11]“Morgan Stanley Group Inc.” Gale Library of Daily Life: Slavery in America, Encyclopedia.com, 2018, www.encyclopedia.com/social-sciences-and-law/economics-business-and-labor/businesses-and-occupations/morgan-stanley, para. 11.
[12]Coombs, Joseph E., and K. Matthew Gilley. “Stakeholder Management as a Predictor of CEO Compensation: Main Effects and Interactions with Financial Performance.” Strategic Management Journal, vol. 26, no. 9, 2005, pp. 827–840.
[13]Hillman, Amy J., and Gerald D. Keim. “Shareholder Value, Stakeholder Management, and Social Issues: What’s the Bottom Line?” Strategic Management Journal, vol. 22, no. 2, 2001, pp. 125–139.
[14]Gilley, K. Matthew, et al. “The Bottom-Line Benefits of Ethics Code Commitment.” Business Horizons, vol. 53, no. 1, 2010, p. 32.
[16]Ruiz-Palomino, Pablo, et al. “Ethical Culture and Employee Outcomes: The Mediating Role of Person-Organization Fit.” Journal of Business Ethics, vol. 116, no. 1, 2012, pp. 173–188.
[17]Kaur, Japneet. “Exploring Relationships among Ethical Climate Types and Organizational Commitment.” Journal of Indian Business Research, vol. 9, no. 1, 2017, pp. 20–40.
[18]Valenzuela, Leslier M., et al. “Impact of Customer Orientation, Inducements and Ethics on Loyalty to the Firm: Customers’ Perspective.” Journal of Business Ethics, vol. 93, no. 2, Aug. 2009, pp. 277–291.
[19]Lindsay, Sally, et al. “A Systematic Review of the Benefits of Hiring People with Disabilities.” Journal of Occupational Rehabilitation, 2018, pp. 1-22.
[20]Bendixen, Michael, and Russell Abratt. “Corporate Identity, Ethics and Reputation in Supplier–Buyer Relationships.” Journal of Business Ethics, vol. 76, no. 1, 2007, pp. 69–82.
[21]Gullett, Josh, et al. “The Buyer–Supplier Relationship: An Integrative Model of Ethics and Trust.” Journal of Business Ethics, vol. 90, no. S3, 2009, pp. 329–341.
[22]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 1.
[23]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 1.
[24]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 1.
[25]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 1.
[26]http://www.morganstanley.com/content/dam/msdotcom/en/assets/pdfs/Code-of-Conduct-2018.pdf
[27]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, pp. 1-2.
[28]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 2.
[29]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 1.
[30]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 2.
[31]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 2.
[32]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 3.
[33]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, pp. 1-2.
[34]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 2.
[35]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 3.
[36]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 7.
[37]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 3.
[38]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 3.
[39]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 2.
[40]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 3.
[41]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 2.
[42]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 3.
[43]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 3.
[44]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 4.
[45]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 3.
[46]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 5.
[47]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 4.
[48]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 5.
[49]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 4.
[50]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 4.
[51]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 4.
[52]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 4.
[53]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 5.
[54]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 5.
[55]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 5.
[56]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 6.
[57]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 6.
[58]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 6.
[59]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 3.
[60]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 2–3.
[61]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 6.
[62]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 7.
[63]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 7.
[64]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 6.
[65]https://www.morganstanley.com/about/company/governance/pdf/Code_of_Ethics_062008.pdf, p. 6.
[66]https://www.morganstanley.com/about-us-governance/pdf/Code_of_Ethics_and_Business_Conduct.pdf, p. 9.
[67]https://ms.taleo.net/careersection/2/jobdetail.ftl, para. 3.
[68]https://ms.taleo.net/careersection/2/jobdetail.ftl, para. 3.
[69]“Banking Regulation 2018 | USA | Laws and Regulations.” Global Legal Insights, 2019, https://www.globallegalinsights.com/practice-areas/banking-and-finance-laws-and-regulations/usa#chaptercontent1, chap. 2.
[70]“Giving Back.” Morgan Stanley, https://www.morganstanley.com/about-us/giving-back
[71]“Global Volunteer Month.” Morgan Stanley, www.morganstanley.com/global-volunteer-month
[72]“Diversity.” Morgan Stanley, https://www.morganstanley.com/people/financial-advisors/diversity
[73]Partnoy, Frank. FIASCO: Blood in the Water on Wall Street.Profile, 2009, p. 89.
[74]Partnoy, Frank. FIASCO: Blood in the Water on Wall Street. Profile, 2009, p. 104.
[75]Horwood, Clive. “Awards for Excellence 2017: Morgan Stanley Reclaims the Investment Banking Throne.” Euromoney, www.euromoney.com/article/b13py2hjs0n5r5/awards-for-excellence-2017-morgan-stanley-reclaims-the-investment-banking-throne
[76]“Abu Dhabi Commercial Bank Et Al v. Morgan Stanley & Co. Incorporated Et Al.” Justia Dockets & Filings, dockets.justia.com/docket/new-york/nysdce/1:2008cv07508/331416/
[77]“FINRA Sanctions Four Firms $9.1 Million for Sales of Leveraged and Inverse Exchange-Traded Funds.” Certified Private Wealth Advisor (CPWA) | FINRA.org, 1 May 2012, www.finra.org/newsroom/2012/finra-sanctions-four-firms-91-million-sales-leveraged-and-inverse-exchange-traded
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