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Applying the EDM could have helped Jim to:

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Recognize the ethical issue:

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Video placeholder

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This includes enrolling and activating all of his brokerage accounts for KICS

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Broker Import so that the investments in these accounts are properly

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reflected in KICS in an accurate and timely manner. It is a violation

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of firm policy to fail to activate a brokerage account for KICS Broker Import

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timely, regardless of the value of the investments in the account.

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Evaluate the ethical issue:

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Jim should review the firm’s personal investment reporting policies

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to confirm that the account should be activated for KICS Broker Import

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and that he should self-report the matter as a violation. He should not try

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to rationalize a poor decision by thinking that an insignificant amount of

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money invested relieves him of his compliance requirement.

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He should also consider his alternatives: doing nothing, transferring

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the investments to his activated account and saying nothing, or

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contacting Risk Management - Independence for assistance.

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Decide how to address the ethical issue:

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Jim should pause to reflect on all available options before he decides

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on a resolution. Jim may be concerned about the repercussions of late

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enrollment and activation of the account in KICS Broker Import.

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Act to address the ethical issue:

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Jim should enroll and activate the account for KICS Broker Import

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in accordance with firm policy, sell any restricted entities and

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self-report the violation to Risk Management – Independence using the

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Independence Inquiry Submission Form on the Independence portal.

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Self-reported violations typically do not incur financial sanctions.

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