60 James Keith, CFA, manages a fund that replicates the S&P 500 index. He uses two brokers, Broker 1 and Broker 2, to which he pays execution-only commission rates. Broker 1 offers Keith an all-expenses-paid trip to a biodiversity conference if he generates sufficient soft dollar commissions. Keith is interested in the conference because he is interviewing for ESG fund manager jobs. He then directs all his trades to Broker 1, which results in generate enough soft dollars to attend the conference.

Did Keith's actions violate the Standards?