#Imran siddiqui code#

Dang,вЂќ commented an Apollo spokesperson in a statement sent to Insurance Business. вЂњWe are pleased with the arbitratorвЂ™s decision and believe it fully vindicates our position regarding the conduct of Mr. вЂњPursuant to the terms of the limited partnership agreements that Siddiqui and Dang had signed, they were not permitted to engage or participate in any competitive business.вЂќДЄpollo has been awarded damages against Dang in the amount of $1 million compensatory damages against Siddiqui and Caldera in the amount of $75,000 as well as punitive damages against Siddiqui in the amount of $150,000. Another company (a Blackstone-controlled entity) was the winning bidder, but this episode demonstrates how both Siddiqui and Dang were working at cross-purposes with their employer. вЂњSiddiqui even went so far as to, in effect, grant Dang access to FGLвЂ™s virtual data room. вЂњAt the same time that Siddiqui was working actively on an Apollo bid for FGL, which was a public company, he, with the assistance of Dang, was working on CalderaвЂ™s efforts to acquire FGL,вЂќ added Segall. Neither Dang вЂ“ who in 2017 was spending as much as four to five hours per day on Caldera matters вЂ“ nor Siddiqui sought the required approval.

As per the code, engaging in an outside business activity requires the approval of ApolloвЂ™s chief compliance officer. Meanwhile it was also highlighted that вЂњmany active stepsвЂќ were taken by Siddiqui and Dang to conceal their involvement. According to the arbitration document, he was involved early on in the venture but no longer had any meaningful involvement by some point in 2017. Siddiqui bought Dang a laptop for his use on these matters.вЂќДaula was a chief risk officer at ApolloвЂ™s insurance company affiliate Athene Holding. Dang was involved actively in efforts to solicit Apollo investors to do business with Caldera going forward. Around the same time Dang began working surreptitiously on these matters and began using his fiancГ©вЂ™s Gmail account for that purpose. There are at least four examples of this.

вЂњInformation from these documents was incorporated into decks and models Caldera was using to solicit potential investors to invest in Caldera. There are at least five such examples from July 2016 through January 2017. Starting in July 2016 and continuing regularly thereafter, Siddiqui, while an Apollo partner, began sending internal Apollo reports, decks, and analyses from his personal Gmail account to the personal email accounts of Cernich, Daula, and Dang.

#Imran siddiqui code#

The arbitrator added: вЂњBeginning in mid-2016, Siddiqui and Dang began to engage in conduct that violated both the letter and the spirit of the Code of Ethics. These include protecting business-sensitive information such as financial information about the group and its clients. Segall noted that the code sets forth minimum standards that are expected of all Apollo employees. Siddiqui conceded that he was bound to comply with the code, but Dang made the ridiculous claim that he did not know whether he was bound or not, and his counsel argued that as a limited partner he was not bound by the code, an argument that is belied by the language of the code itself and the testimony by several other witnesses on this subject at the arbitration hearing.вЂќ вЂњBoth Siddiqui and Dang participated in trainings and certified their compliance with the code on an annual basis. Becoming limited partners in Apollo carry vehicles neither changed their basic employment relationship nor did it relieve them of their obligations and duties under the code. throughout their tenure at Apollo, and that entity paid their salaries and issued them W-2s. вЂњBoth Siddiqui and Dang were employees of Apollo Management L.P. вЂњApollo has a Code of Ethics,вЂќ stated arbitrator Mark E. Ming Dang, meanwhile, was working full-time as an Apollo principal when he started to work with Siddiqui and Caldera co-founder Stephen Cernich on the Bermuda-incorporated entity.