Alan, who is the Chief Financial Officer of SNL, has become aware that the company is seeking to tender for some major renovation work needed by the company. Alan's cousin is in the renovation business so Alan tells him of the possibility of work at SNL. Alan tells his cousin the price range that SNL will consider and something about other companies that are tendering. Alan attends the meeting where they consider who will get the tender for the repair work, but does not disclose his connection with his cousin, who has put in a tender and actually wins the contract.

Does Alan have any potential liability for what he has done or not done?