G. Capern, J. Larry and J. Elders, for appellant Mitchell
G. Azeff, for appellant Paul Azeff.
S. Bieber and T. Liu, for appellant Howard Jeffrey Miller.
J. Wright and G. Temelini, for appellant Man Kin (Francis)
A. Perschy, J. Lynch, P. Foy and A. Matushenko, for respondent.
The judgment of the court was delivered by
 NORDHEIMER J.: — There are four appeals, pursuant to
s. 9(1) of the Securities Act, R.S.O. 1990, c. S.5 (the “Act”), from a
decision of a panel of the Ontario Securities Commission (the
“Panel”) dated March 24, 2015 [Azeff (Re), 2015 LNONOSC 142],
where each of the appellants was found to have passed along
material non-public information, other than in the necessary
course of business, contrary to s. 76(2) of the Act. The appellants,
other than Finkelstein, were also found to have engaged in
insider trading and to have acted contrary to the public interest.
Each of the appellants also appeals from the decision and order
of the Panel, dated August 24, 2015 [Azeff (Re), 2015 LNONOSC
525] imposing sanctions and costs.
I: RELATIONSHIPS BETWEEN THE APPELLANTS
 Mitchell Finkelstein was a successful corporate and com-
mercial lawyer at Davies Ward Phillips & Vineberg LLP
(“Davies”) in Toronto from 1997 to 2010. Paul Azeff was employed
as an investment advisor at CIBC in Montreal between 2004 and
2007, the period relevant to this proceeding. Azeff and Finkelstein
were good friends. They attended each other’s weddings. Azeff
was Finkelstein’s investment advisor during such time. Finkel-
stein and Azeff communicated frequently during the years 2004
 Azeff and Bobrow have been extremely close friends since
high school. The pair have worked together since 1995, moving
firms in lockstep. While at CIBC, they worked together effectively as partners: they had adjacent desks, they shared a trading code for all their trading, they discussed investment ideas
continuously, they shared their research and they looked after
each other’s clients.
 Miller was a very experienced and successful investment
advisor who had more than 15 years’ experience in the securities
industry. He was a vice-president and a senior investment advisor at TD Securities. He had been a registrant since 1995.