The Securities & Futures Commission has reprimanded Sarasin Rabo Investment Management Limited and its responsible officer Simon John Ruckert for the company's inadequate internal controls.

The commission has agreed to accept a voluntary payment of $400,000 from Ruckert in settlement of the disciplinary action against him.

The company reported to the commission that one of its licensed representatives had conducted unauthorised transactions in three client accounts, from October 2002 to March 2003, which resulted in losses in one account amounting to around US$1 million.

The commission found certain internal control failings in the company which made it possible for the representative's misconduct.

The internal control failings also helped the representative to withhold margin call letters from the client and disregard reminders from the company to inform the client to collect his hold mail.