ESTEVEZ $($Case $6$ Supervisory Reponsibility$)$

Estevez is the chief compliance officer of a global financial services corporation. He and his staff

develop and implement policies and procedures to address antibribery and corruption issues. The

policies prohibit employees from providing $$anything of value$$ to government officials to gain an

improper business advantage. The policies specifically define $$value$$ to include job offers or

employment to individuals at the request of a client, potential client, or official of a government or

state owned enterprise. The policy also prohibits employees from hiring anyone as a temporary

employee, intern, or in other roles in an attempt to evade the policy. The company uses a

questionnaire that requires employees seeking to hire a referral candidate to disclose the source of

the referral, identify whether the referral source is a client or prospective client, and disclose

whether the potential hire was referred by or related to a government official. The compliance

policies require the questionnaire to be submitted to both the compliance and the human

resources departments for approval.

On multiple occasions, senior members of the company$$s Asia$-$Pacific $($APAC$)$ office, seeking to

obtain or retain business, attempt to hire relatives of state$-$owned enterprises and government

officials, but these applications are rejected by Estevez as violations of the firm$$s compliance

policies. The firm$$s APAC officials then direct a regional$-$affiliated organization to hire the referred

individuals. As employees of the affiliate, these referral hires are permitted to do work for the firm.

Several months later, the employees, having gained experience, are brought into the firm as lateral

hires from the firm$$s affiliate.

Choose the response that best describes how Estevez met his professional responsibilities with

respect to the CFA Institute Code of Ethics and Standards of Professional Conduct $($Code and

Standards$).$ Estevez Supervisory Responsibility $$ Case $6$

A$.$ drafted comprehensive compliance policies regarding referral hires.

B$.$ fulfilled his responsibilities because he rejected the APAC officials$$ attempts to hire individuals

in violation of the firm$$s policies.

C$.$ properly allowed referred hires to gain experience at an affiliate prior to joining the firm.

D$.$ did not appropriately meet his professional responsibilities under the Code and Standards.

E$.$ none of the above.