Is a director or officer required to rectify oppression personally?

Gottlieb v. Adams recognizes that the conduct of directors or officers must be conduct qua directors or officers if it is to afford access to the remedial powers under the oppression remedy. The further question whether the director or officer should be required to rectify that oppression personally is determined by all of the circumstances including the nature of the oppression, the gain if any which flowed to the director or officer, and the effects of other possible orders on other security holders.