Question 1 of 30
Quantum Investments, a rapidly growing portfolio management firm, is experiencing increased scrutiny from regulators following several client complaints regarding potential conflicts of interest. The firm\'s Code of Ethics, while present, lacks specific guidance on managing personal investments of portfolio managers in companies that are also held within client portfolios. Furthermore, there is no formal process for disclosing these potential conflicts to clients or obtaining their informed consent. Several portfolio managers have been actively trading in securities of companies that Quantum Investments recommends to its clients, raising concerns about potential breaches of fiduciary duty. The Chief Compliance Officer (CCO) is now tasked with strengthening the firm\'s approach to ethical conduct and conflict management. Considering the requirements of National Instrument 31-103 and the principles of fiduciary duty, which of the following actions represents the MOST comprehensive and effective strategy for Quantum Investments to address these concerns and mitigate future risks?
Develop a detailed Code of Ethics that explicitly addresses potential conflicts of interest, including personal investments of portfolio managers, establishes a formal process for disclosing conflicts to clients and obtaining informed consent, and implements independent review mechanisms to monitor and enforce compliance.
Implement a policy requiring portfolio managers to disclose their personal investments only when directly questioned by clients, while relying on the firm's reputation to ensure ethical conduct.
Focus solely on enhancing internal training programs for portfolio managers, emphasizing the importance of ethical behavior without establishing formal disclosure or review processes.
Restrict all personal trading activities by portfolio managers, regardless of whether a conflict of interest exists, to avoid any appearance of impropriety.

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