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TTSEC Code Of Conduct Quiz

Instructions

This Quiz is designed to evaluate your familiarity with the Code of Conduct of the Trinidad and Tobago Securities and Exchange Commission (“the Commission”). Please note the following:

This Quiz is mandatory for all employees of the Commission and for all OJTs assigned to the Commission;
Once you start the Quiz, it should take you approximately 60 minutes to complete it. However, if you are unable to complete the Quiz in one sitting we ask that you please contact the Office of the Corporate Secretary and arrangements will be made for you to complete the Quiz;
The pass mark for the Quiz is 32/38. You will receive a certificate once you pass.
You should only complete the Quiz once. You are only required to re-take the Quiz if you do not achieve the pass mark on your first attempt. In such a case, you will be invited to do so after meeting with the Corporate Secretary.
You may refer to your copy of the Code of Conduct (issued in February 2016) while completing the Quiz, however, you may not collaborate with another person.

Please enter your Full Name:

APPLICABILITY/ELIGIBILITY

You have been approached by a new member of staff in your division/department who overheard other staff members claiming that the code of conduct (“the code”) applies to only certain staff members and not the Commissioners. Would you advise that:

A. As far as you understand, that is accurate.

B. The code applies only to staff members who have previously breached some aspect of the code

C. The code applies to all Commissioners and all employees of the Commission

Confidentiality

While traveling in a maxi, you receive a phone call from your colleague who requesting information on a matter to be discussed at A meeting that is about to start. You realise that you will likely arrive 30 minutes after the meeting is scheduled to begin. Do you

A. Provide the update because you will not reach in time for the meeting

B. Explain that you are in public and cannot discuss the matter

C. Provide the update without mentioning the names of individuals or companies

Gifts

It’s the season to be jolly and you receive as a gift, a bottle of alcoholic beverage from a registrant to whom you provided requested information. What should you do with the gift?

A. Use it to toast at your division’s end of year event

B. Keep it for your personal use during the festive season

C. Pass the gift to the HR Department for return because you are sure that the cost of the gift exceeds the $500.00 nominal value for unsolicited gifts

Political Activity

While leaving the office on a Friday evening, dressed in your Commission-branded polo, you encounter a protest taking place outside of the parliament building. The protestors are all dressed in t-shirts bearing the colour and logo of a political party, and you realise that the protest is based on an issue that you are passionate about. Do you:

A. Join the protest because you have no other plans

B. Walk past the protest, but give an on-camera interview to reporters nearby

C. Forego participation in the protest because you are wearing the commission’s uniform

Interpretation: Confidential information

The definition of confidential information for the purpose of the Code of Conduct is limited to the Securities Act

A. True

B. False

Responsibilities

Which of the following statement is true?

A. The chief executive officer shall ensure that all employees are informed of the code and are compliant with it

B. The general counsel/corporate secretary shall ensure the Board’s compliance with the code

C. The human resources department shall be responsible for the overall administration of this code

Use of prescription drugs

You fall ill and your doctor prescribes medication and clears you to report for work. However, he warns that you may experience serious side effects, while taking the medication. You have been feeling fine since taking the medication before leaving the house. Do you?

A. Inform your supervisor, so that he/she will be able to properly respond in the event that you have an adverse reaction

B. Confide in a colleague who works in another department because you’re afraid that telling your supervisor will result in you missing out on a valuable training opportunity

C. Keep your confidential medical issues to yourself because you don’t believe it’s work related

Whistleblowing

You and your colleagues are assigned to deal with a sensitive matter involving a registrant. While working on the matter, you discover that one of your team members has a close relative who is employed with the registrant. Your colleague ignores your advice to disclose his relationship, and you report it to your head of department, who also ignores your report (as he does not want to get your colleague in trouble.) To whom should you complain?

A. HR and/or the CEO

B. The general counsel and/or internal audit manager

C. The ministry of finance

Declaration of Interest

Your husband (joint account holder) purchased 10,000 shares in a registrant without telling you? You only find out when you receive the statement of account a month after the purchase:

You should:

A. Declare immediately upon finding out the information

B. Do nothing since you have no control of your husband’s actions

C. Do nothing since although your name was on the shares they were purchased with your husband’s money

Purpose

You are witness to a heated debate among some colleagues during lunch break re the purpose of the code. Which of the following views expressed do you think accurately reflects the purpose for which the code was designed?

A. To simply ensure that staff show respect to each other and its registrants

B. To guide the standards of performance expected of you to ensure that the commission’s business is conducted with integrity and complies with all applicable laws, regulations and policies

C. To ensure that deliverables are honored in a timely manner

Dealing in Securities

You are vaguely aware that the commission is handling the registration of a new security of a company that produces green energy. You are an avid environmentalist and want to support this venture. Do you?

A. Buy as many shares as possible at the earliest opportunity – after all you want to ensure the success of this venture for the children of the country;

B. Seek the permission of the ceo before attempting to purchase shares in the company;

C. Don’t participate but get your mother to buy the shares and hold on trust for you.

Participation in Associations

The mutual funds association of Trinidad and Tobago has invited you to become a member and to participate in the preparation of a report on the progress of collective investment schemes over the last 20 years. Do you?

A. You jump at the opportunity since this is a chance to showcase all your knowledge gained while at the Commission

B. Offer to be a ghostwriter of the report

C. Decline as this would be a conflict of interest with your position at the Commission.

Confidentiality

You get together socially with a friend who is a journalist, who is writing a story on securities in T&T, he/she knows that you work at the Commission, and wants to discuss some sensitive issues off the record. Do you?

A. Speak freely with your friend because the conversation is “off the record”

B. Discuss some issues that you think are not confidential, but be careful not to mention others

C. Remember the obligations contained in the confidentiality declaration and not discuss any work related matters

Legal Requirementss

Are all staff required to comply with the Commission’s policies, procedures and guidelines?

A. Yes (all are required)

B. No (some are exempt)

Entertainment

You are invited to a registrant’s staff awards function and cocktails in your personal capacity. You should?

A. Attend the function

B. Decline the invitation

C. Inform the CEO of your intention to attend as it would be a good networking opportunity

Discrimination

The Commission has hired a staff member who recently migrated to Trinidad. Other members of staff have been making fun of her accent and impersonating her at the office. They have also recorded the impersonation and placed the video in the department’s whatsapp group (of which the new employee is a member). Is this type of behaviour allowed?

A. Yes, the commission does not get involved in personal issues between employees

B. No, the code of conduct prohibits discrimination

Whistleblowing

An employee makes a report to one of the whistleblowing reporting officers against his/her manager and while the matter is being investigated, the manager gives them a failing grade on their performance appraisal which is unusual for this employee and not in line with their performance over the period under review.

Is this a violation of the code?

A. Yes

B. No

Care and use of equipment, property and environment

Whilst working from home during the covid lock down, the commissioned laptop starts giving trouble. You try many times to reboot it but it’s still not coming on. What do you do?

A. Take is to computer repair shop in your community.

B. Say nothing and wait for your supervisor to call.

C. Promptly report to your supervisor for the issue to be resolved

Political Activity

You receive a phone call inviting you to submit your nomination for candidacy in the Local Government Elections. You are excited and have no hesitation about submitting the required papers. Today is the deadline and you are out of office for the day. Do you

A. Submit the application and inform the Commission when you return to work

B. Contact the Commission and explain the urgency of the matter and ask for it to be considered expeditiously.

Interpretation: Private Interests

Your spouse made a substantial investment in a company five years before you wed. You have been asked to participate in an inspection of the company. Does your spouse’s investment constitute a private interest as defined in the Code of Conduct?

A. Yes

B. No

Use of Illegal Drugs

Kenneth’s salary is unable to meet his monthly expenses and his wife recently had a baby. He knows someone that can give him a little bit of drugs to sell that can help him meet his monthly expenses. What does he do?

A. He should take the drugs and sell it, as his family is dependent on him.

B. He should find another way earn the additional income to support his family.

C. Once he is discrete in selling the drugs he can proceed to do so.

Confidentiality

A family member asks you to use your contacts at the Commission to enquire into the draft prospectus for a new class of shares which will be launched by a registrant, that they are interested in. Do you?

A. Refuse to provide the information and request that he/she make a request to the Commission.

B. Give him the information as it may be public information

C. Give him some information

Participation in Political Party

You have been involved in a political party’s youth group since you were a teen but never represented the party in any way. You were recently approached to be a candidate for the party. What should you do?

A. Take the offer and commence your candidacy after work.

B. Tell your supervisor and once they are aware you accept the offer.

C. Inform the chief executive officer and wait for the participation to be determined that your participation is not in conflict with the Commission's operations in any way

Interpretation: Unauthorized Person

Your friend who is an employee of the Central Bank of Trinidad and Tobago informally asks you for information concerning an ongoing investigation. Should you:

A. Disclose the information because the Securities Act and MOU’s permit information sharing with other regulators

B. Provide informal hints about the status of the investigation because the person is employed with the CBTT anyway

C. Refuse to disclose the information in the absence of a formal request via the prescribed process

Use of Illegal Drugs

Barry has been having a hard time on the job and his wife has asked for a divorce. On his lunch break, he leaves the Commission's premises and smokes a small amount of marijuana before returning to work.

A. This is permissible since it’s a small amount and he is not smoking on the Commission’s premises

B. This is not permissible since the Commission’s employees are not permitted to use illegal drugs at any time

C. Once he is able to function effectively on the job it doesn’t matter

Unauthorised Person

The Legal division has commenced an investigation regarding a registrant, with whom your family member is employed. Only selected staff members were authorised to work on the matter, however, you hear whispers about the action that the Commission is about to take. Do you?

A. Inform your family member of the action the Commission is going to take against the registrant

B. Start enquiring from other colleagues about what is happening in the matter and inform your family member

C. Tell your family member nothing as you are not authorised to disclose any information

Conflict of Interest

Registrant X calls the Commission frequently and you professionally assist him at all times. Registrant Y calls and is very unpleasant and you find him annoying. Do you?

A. Ignore him and put his file to the bottom of the pile

B. Give him a good piece of your mind, because you’re not feeling well

C. Maintain your professionalism, consult with your supervisor and do what you can to address his issues/concerns

Gambling

You and some of your colleagues are avid cricket fans. You will be unable to attend the upcoming Trinbago Knight Riders v. Barbados Tridents fixture, as the match would be played during working hours. To channel your excitement, you decide to run a small and discreet betting pool at the office. Is this allowed?

A. Yes

B. No

Interpretation: Family

The definition of family for the purpose of the Code of Conduct is limited to persons who reside within your household

A. True

B. False

Dealings in Securities

Employees of the Commission purchase securities in an IPO, advertised to yield a high return. The employees are happy with their investment until a month into the purchase, when they receive information that the yield may not be as favourable as they believed. This information is not in the public domain. What would be the correct action for the employees to take?

A. Transfer your interest to a friend

B. Do nothing - employees are not allowed to act on non-public information to secure investments

C. Sell the security as quickly as possible

Discrimination

I have been an employee of the Commission for five years and have gained considerable experience in different areas. My direct supervisor refuses to send me on training and would normally make remarks about my age and that it makes no sense training me as I have a few years to retirement.

Would his/her actions amount to discrimination?

A. Yes

B. No

Raffles & Donation Sheets

You are a member of the PTA of your child’s school. The school has issued donation sheets to raise funds to outfit its new science laboratory. Do you?

A. Circulate the donation sheet within your department

B. Seek permission from the CEO before circulating the donation sheet

C. Circulate the donation sheet among colleagues in other departments, with whom you have a close relationship

External Employment

You are offered a weekend job with a foreign based company. You are aware that the company is involved in some form of trading activity, but you are unsure whether the company is a registrant, and/or if its activities would be regulated by the Commission. Do you:

A. Accept the job because you need the money, and you can easily resign if you later find out that there will be a conflict

B. Consult with the CEO to determine whether there may be a conflict

C. Accept the job on the condition that the company not disclose your affiliation with them, as it may conflict with your duties at the Commission

Confidentiality

You are contacted by someone on Linked-in, asking about a Registrant who is being investigated for a Breach of the Securities Act, Chap. 83:02. Do You?

A. Respond on Linked-in providing the information (no one will know).

B. Send the information in a WhatsApp message.

C. Obtain written approval from the CEO to make the information available.

Safe keeping of the Commission’s equipment

It’s been a long day at work and you still have a task to complete. You decide to take home your laptop, so you place it on the front seat of your car. While on your way home, you realize that you need to stop at the supermarket. Do you?

A. Leave the laptop on your front seat and Run into the supermarket as it will just take a few minutes

B. Secure the laptop out of sight in the vehicle and lock the vehicle

Care and use of Equipment, Property and Environment

You sneak a glance at your cellphone during a meeting and notice that your best friend sends you a WhatsApp message with a trending video of a popular celebrity in a compromising position. You are unable to view the video on your cellphone. Do you:

A. Connect to WhatsApp web via your Commission-issued laptop and download and discreetly watch the muted video

B. Excuse yourself from the meeting and watch the video on your cellphone via the commission’s Wi-Fi

C. Go to your colleague’s cubicle and watch the video on his/her Commission-issued desktop computer

D. None of the above

Use of Alcohol

Denise has been mixing vodka in her coffee each morning because she needs to be calm when communicating with her annoying supervisor.

Which of the following statements is true?

A. Denise cannot be reprimanded once the alcohol does not impair her ability to do her job

B. Denise can be asked to undergo a random drug test or medical exam

C. Denise cannot be asked to do a random drug test, since this may amount to discrimination if she is the only person in her unit who is asked to do so

Entertainment

You receive a special award in the form of a plaque from a registrant for “excellent customer service”. You should?

A. Accept the award and display it on your desk at work

B. Accept the award at that point and return it subsequently with an explanation

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