Appropriately assess risk when business decisions are made, demonstrating particular consideration for the firm's reputation and safeguarding Citigroup, its clients and assets, by driving compliance with applicable laws, rules and regulations, adhering to Policy, applying sound ethical judgment regarding personal behavior, conduct and business practices, and escalating, managing and reporting control issues with transparency. Adhere to a specific prospecting code of conduct, which (1) permits acquiring new private client accounts only by referral or personal contact with an individual seeking to do business and (2) prohibits seminars, mail campaigns, cold calling and any other methods of solicitation.