Procedures for compliance

Many firms require employees and their families to report all transactions by employees and their families for purposes of detecting conflicts of interest and trading on material nonpublic information. If this exists or not, you should report to employers, clients, and prospective clients any material beneficial interest you may have in securities and any corporate directorships or other special relationships they may have with the companies you are recommending. Members should make the disclosures before they make any recommendations or take any action regarding such investments.

There are two approaches to avoid potential conflicts of interest:

• Avoidance: Personal investment through "blind trust" or "mutual fund," in which you have no influence on investment decisions.
• Disclosures: As soon as the member has made full disclosure of the potential conflict, the client has all the relevant information to allow him or her to make a decision regarding the investment.