Anderb, a portfolio manager for XYZ Investment Management Company, a registered investment organization that advises investment companies and private accounts, was promoted to that position three years ago. Bates, her supervisor, is responsible for reviewing Anderb's portfolio account transactions and her required monthly reports of personal stock transactions. Anderb has been using Jonelli, a broker, almost exclusively for portfolio account brokerage transactions. For securities in which Jonelli's firm makes a market, Jonelli has been giving Anderb lower prices for personal purchases and higher prices for personal sales than Jonelli gives Anderb's portfolio accounts and other investors. Anderb has been filing monthly reports with Bates only in those months in which she has no personal transactions, which is about every fourth month. Which of the following apply (applies)?

I. Anderb violated the Code and Standards in that she failed to disclose to her employer her personal transactions.
II. Anderb violated the Code and Standards by breaching her fiduciary duty to her clients.
III. Bates violated the Code and Standards by failing to enforce reasonable procedures for supervising and monitoring Anderb in her trading for her own account.