Applying the EDM could have helped Jim to:
Recognize the ethical issue:
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This includes enrolling and activating all of his brokerage accounts for KICS
Broker Import so that the investments in these accounts are properly
reflected in KICS in an accurate and timely manner. It is a violation
of firm policy to fail to activate a brokerage account for KICS Broker Import
timely, regardless of the value of the investments in the account.
Evaluate the ethical issue:
Jim should review the firm’s personal investment reporting policies
to confirm that the account should be activated for KICS Broker Import
and that he should self-report the matter as a violation. He should not try
to rationalize a poor decision by thinking that an insignificant amount of
money invested relieves him of his compliance requirement.
He should also consider his alternatives: doing nothing, transferring
the investments to his activated account and saying nothing, or
contacting Risk Management - Independence for assistance.
Decide how to address the ethical issue:
Jim should pause to reflect on all available options before he decides
on a resolution. Jim may be concerned about the repercussions of late
enrollment and activation of the account in KICS Broker Import.
Act to address the ethical issue:
Jim should enroll and activate the account for KICS Broker Import
in accordance with firm policy, sell any restricted entities and
self-report the violation to Risk Management – Independence using the
Independence Inquiry Submission Form on the Independence portal.
Self-reported violations typically do not incur financial sanctions.