Nan Huang was a senior data analyst for Capital One Financial Corporation. In violation of the company’s confidentiality policies, Huang downloaded and analyzed confidential information regarding purchases made with Capital One credit cards at more than 200 consumer retail companies and used that information to conduct more than 2,000 trades in the securities of those companies. Capital One terminated Huang due to his violation of the company’s policies. The next day, Huang boarded a flight to his home country of China. Four days later, the Securities and Exchange Commission filed a complaint against Huang, alleging violations of Section 10(b) and Rule 10b-5. [ Securities and Exchange Commission v. Bonan Huang, 684 Fed.Appx. 167 (3d Cir. 2017)] (See The Securities Exchange Act of 1934.) 

(a) Evaluate the ethics of Huang’s actions, as an employee of Capital One, using the IDDR approach.

(b) When Capital One learned what Huang had done, was the company ethically obligated to terminate him? Explain.