Two friends, Matt and Joshua meet for lunch. Matt is CFO of a large Information

Technology firm and mentions that quarterly results look very good during lunch.

Joshua, an investment adviser, writes a research report to clients suggesting they buy

shares of a Technology ETF that includes shares of Matt's company, due to the

potential for high industry sales the coming quarter. Joshua also buys shares of the

ETF for his personal account.

Joshua violated the Code and Standards by buying shares of the fund but not by

making the recommendations to clients

Joshua did not violate the Code and Standards by either action because he did

not directly act on information by buying shares of Matt's company

Joshua violated the code of conduct by both actions, buying shares of the fund

and recommending that clients do so