Andrea Petersen, CFA is an analyst for CCM Investment Managers and covers firms

in the Heavy Machinery industry. She has recently accepted an invitation to visit the

facilities of Carlyle, a supplier of parts to Original Equipment Manufacturers in the

Heavy Machinery industry. Carlyle allows Andrea to use the company's private jet to

travel to its facilities in Rome and Sao Paolo. In addition, Carlyle offers her tickets to

a high society dinner in London. She rejects the offer to use the company private jet

but accepts the dinner invitation because she reasoned the dinner might offer the

opportunity to meet potential clients for her company's mutual funds and other

financial products. She discloses to her employer that she accepted dinner tickets

from Carlyle. Did Andrea violate any code of conduct?

Yes

No$,$ since she rejected the opportunity to fly in the company jet and only

accepted the dinner tickets because she wants to use the opportunity to benefit

her employer

No$,$ since she fully discloses to her employer that she accepts dinner tickets,

which are of a nominal value anyway