Ethical Compliance with Nonpublic Information

Sarah is a portfolio manager at Wealth Management Firm. During a casual conversation at a networking event, she learns about an upcoming merger involving one of her clients, a publicly traded company. Recognizing the sensitivity of this nonpublic information, she refrains from making any trades based on this knowledge immediately. However, the next week, she casually discusses her thoughts on the potential impact of mergers in general with her colleagues, without specifically mentioning the name of her client’s company.

A few days later, she finds out that her friend, who doesn’t work in finance, trades stocks based on information he had overheard in the same conversation at the networking event. Which of the following actions best represents Sarah’s compliance with the CFA Institute's Code of Ethics and Standards of Professional Conduct regarding nonpublic information?