My wife has 5% of the shares and is a board member, Can I buy shares for my clients?

CFA Level I Ethics
#1

Dear forum members,

I’m CFA level 1 candidate and have a doubt that may be for the interest of the community. Imagine this situation:I manage investment portfolios for Ultra High net worth individuals and my wife has 5% stake of a company in S&p500 and is a non- executive board member since 2010. I’m a portfolio manager and only by looking to the dynamics of the sector, competitive position of the company, the financials, product pipeline, executive management experience, I reach the conclusion that the company is undervalued and share price should be 40% higher. Can I buy this shares my clients? In terms of independence is acceptable?

I appreciate in advance the time you’ve spent reading this question,

Best Regards

#2

Make the disclosure when recommending this stock. Tell your clients that you have made a reasonable well done research and you consider the stock is undervalued, so it is a buy. State that your wife owns the 5% of that company and she is not a managerial employee for at least 5 years. If the stock is very liquid, I think nobody will claim nothing.

#3

Thank you for your help