ETHICAL DECISION MAKING
CFA SOCIETY OF WESTERN MICHIGAN
14 NOVEMBER 2012
Michael G. McMillan, Ph.D., CPA, CFA
Director, Ethics and Professional Standards
Twitter: @M_G_McMillan
http://blogs.cfainstitute.org/investor/author/michaelmcmillan/
MISSION STATEMENT:
To lead the investment profession
globally by setting the highest
standards of ethics, education, and
professional excellence for the
ultimate benefit of society.
Ethical Decision Making
CFA INSTITUTE INTEGRITY LIST
1. Commit to a gold standard code of ethics and professional
conduct [See CFA Institute Code of Ethics and Standards of
Professional Conduct].
2. Require training on ethical decision-making for yourself and
your firm.
3. Place the client’s interests before your own.
4. Name and shame unethical behavior.
5. Recommend products with transparent payoffs, costs, and
risks.
6. Help clients focus on risk as much as they do on performance.
7. Disclose your educational achievements and how you improve
professional competence.
8. Strive for a conflict-free business model.
9. Advocate for stronger regulations that protect investors.
10. Act with integrity 24/7 – not just at the office.
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ETHICAL DECISION MAKING
Resolving Dilemmas: Issue Spotting & Analysis
- Effective
- Thinking about:
- Honesty
- Integrity
- Character
- Suitability
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THE GOAL OF ETHICS TRAINING
• To encourage you to become more conscious about your
thoughts and behaviors so that you are more likely to
notice, and act upon, ethical issues before they become a
problem.
• To recognize that ethical dilemmas are a normal and
predictable part of most jobs.
• To discuss approaches for dealing with ethical issues.
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THE SITUATIONAL VS. DISPOSITIONAL
- Situational influences have more to do with
unethical behavior than a person’s character.
- Under the right conditions good people can be
induced, seduced, and initiated to act
unethically.
Philip Zimbardo, Professor Emeritus, Stanford University
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ETHICS VS. COMPLIANCE
Compliance: ensures that
employees conform to a set of
required behaviors.
Ethics: encourages employees
to behave in way that is
consistent with the
organization’s values and
mission.
• You must…
• You should…
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FUNDAMENTAL ETHICAL PRINCIPLES
-
Client interests come first
Maintain independence and objectivity
Avoid/manage conflicts of interest
Full and fair disclosure
Preservation of confidentiality
Fair dealing
Reasonable care & prudent judgment
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RATIONALIZING UNETHICAL BEHAVIOR
- Everybody else does it, so it must be okay.
- That is the way they do it at Firm X.
- If we do not do it, someone else will.
- This is the way it has always been done.
- It doesn’t really hurt anyone.
- It’s not a big deal.
- It’s not my responsibility.
- I want to be a team player; l want to be loyal.
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ETHICS & INVESTING?
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RESOLVING ETHICAL DILEMMAS
1. Acknowledge that there is an ethical issue.
2. Determine who is faced with and owns the problem.
3. Gather the relevant data.
4. Test the wrong vs. right parameters.
5. Test for right vs. right paradigm.
6. Apply the resolution principles.
7. Investigate 3rd way options – compromise.
8. Make a decision.
9. Reflect on what you learn from the decision.
Ethical Decision Making
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“I want employees to ask themselves whether
they are willing to have any contemplated act
appear the next day on the front page of their
local paper – to be read by their spouses,
children and friends-with the reporting done
by an informed and critical reporter.”
Warren Buffett, Interim Chairman of the Board, Salomon Brothers
Ethical Decision Making – CFA Society of Cleveland
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Peterson
You are the director of research at a large bank. You hire Peterson to be an
equity analyst. Peterson and your friend Thompson, a senior equity analyst
at the bank, attended university together and were roommates. During lunch
one day, Peterson tells you that there is an error in the bank’s marketing
brochure and website because Thompson, only studied accounting while at
university and not accounting and finance. Back in your office, you check
Thompson’s biographical information online and find references to an
“accounting and finance” degree. What should you do?
A. Say nothing.
B. Contact the Thompson and tell him what
you learned.
C. Contact the marketing department and
tell them about the error.
D. Contact the Thompson’s supervisor and
tell him/her what you have learned.
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A.
Ethical Decision Making
0%
B.
0%
C.
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D.