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Transcript of Business Ethics
More Leading Role
Conflicts of interest
Goldman Sach's Organizational Structure
Kinder Morgan-El Paso Deal
(Conflict of Interest Case)
Reasons Behind the Misconduct
Stephen D. Daniel
, Goldman’s lead banker and partner who is co-head of global energy investment banking in Houston, failed to disclose his own personal ownership of approximately $340,000 in Kinder Morgan stock.
Solution: Creating an effective ethics program
CODE OF BUSINESS CONDUCT AND ETHICS
Creating an ethical culture
Application of the Code
An individual must choose whether to advance his or her own interests, those of the organization, or those of some other group.
Principles and Compendium of Firmwide Compliance Policies
Reporting Issues under the Code
Compliance with Laws, Rules and Regulations
Embodies the firm’s commitment to conduct our business integrity and ethical behavior
Founded in the U.S. in 1869, a multinational investment banking firm that engages in:
Global investment banking
Others (institutional clients.)
Code should be viewed as the baseline of expected behavior at the firm
The Compendium includes policies and procedures to guide you in adhering to the letter and the spirit of all applicable laws, rules and regulations.
Goldman Sach's flat organization has fewer layers of management meaning fewer approvals in decision-making. Though this speeds up the decision-making process, it provides opportunity for individuals to act more freely than usual.
rather than a
An immediate supervisor and a member of the Global Compliance Division or Legal Department
Our clients' interest always come first.
Our assets are our people, capital and reputation.
The firm strictly prohibits retaliation against anyone who reports in good faith a possible violation of the Code
Our goal is to provide superior returns to our shareholders.
We take great pride in the professional quality of our work.
A Comprehensive Code of Conduct
Effective Ethics Training
A Strategic Communications Plan
An Ethics Hotline
Commit to Continuous Improvement
Integrity and honesty are the heart of our business.
creates the right environment to deliver best results.
Responsibility is shared
Nothing in this Code is intended to limit those rights or any protections that may be applicable in connection with reporting potential violations.
You must comply with all applicable laws, rules and regulations, including those related to insider trading, financial reporting, money laundering, fraud, bribery and corruption.
Purchase or sale of any firm securities or any securities of issuers that you are familiar with by virtue of your role at Goldman Sachs should be directed to an appropriate ethics contact prior to any purchase or sale.
You are prohibited from taking for yourself a business opportunity that is discovered through the use of corporate property unless the firm has already been offered the opportunity and turned it down or otherwise renounced the opportunity.
Actions orrelationships that create personal conflicts of interest are prohibited,unless approved by the firm.
Individual operating in his own self-interest
Ethical Culture: Top management's leadership on ethical issues
"It’s not the principle that counts in this business. It’s the money. "
Unfortunately, in this industry being a shark, as most investment bankers are, is good for your reputation.
Peer Banks and Competitors
(Can profit from them)
(Can also profit from them)