16. Jeremy Seagate, CFA, a portfolio manager, has investments in Company 1 and Company 2 for his clients' portfolios. Seagate has a personal relationship with the CEO of Company 1. He discloses this relationship to his employer. Seagate's sister, a standard fee-paying client of his firm, requests to buy a large position in Company 2. The company, as well as the size of the requested investment, are suitable for Seagate's sister. Seagate buys the requested position in Company 2's stock for her and notifies his employer. Did Seagate violate the Standard relating to avoid or disclose conflicts?