C.: Disclose Conflicts between you and your Employer

　　III(C.1):

　　Members shall disclose to their employer all matters, including beneficial ownership of securities or other investments, that reasonably could be expected to interfere with their duty to their employer or ability to make unbiased and objective recommendations.

　　III(C.2):

　　Members shall comply with any prohibitions on activities imposed by their employer if a conflict of interest exists.

　　Compliance: Members should report to their employers any beneficial interest and any special relationships, like corporate directorships, that may reasonably be considered a conflict of interest with their responsibilities. Members should also discuss the situation with their firm’s compliance officer before taking any action that could lead to a conflict of interest.

　　D.: Disclose Additional Compensation from Outside the Firm to your Employer

　　Standard: Members shall disclose to their employer in writing all monetary compensation or other benefits that they receive for their services that are in addition to compensation or benefits conferred by a member’s employer.

　　Compliance: Members should make an immediate written report to their employer specifying any compensation or benefits they receive or propose to receive for services in addition to what their employer is to give them. This written report should state the terms of any oral or written agreement, the amount of compensation, and the duration of the agreement.

　　E.: Responsibilities of Supervisors

　　Standard: Members with supervisory responsibilities, authority, or the ability to influence the conduct of others shall exercise reasonable supervision over those subject to their supervision or authority to prevent any violation of applicable statutes, regulation, or provisions of the Code and Standards. In so doing, members are entitled to rely on reasonable procedures designed to detect and prevent such violations.

　　Compliance: The supervisor and the compliance officer should:

　　1. Disseminate the compliance procedures.

　　2. Update the procedures as necessary.

　　3. Educate the staff and issue periodic reminders.

　　4. Incorporate a professional conduct *uation into the employee’s performance review.