单选题 As part of an agreement with Johnny, TP&C Investment Company, a money manager for individual clients, provides monthly emerging market overviews in exchange for prospective client referrals and European equity research from Johnny. Clients and prospects of TP&G are not made aware of the agreement, but clients unanimously rave about the high quality of the research provided by Johnny. As a result of the research, many clients with non-discretionary accounts have earned substantial returns on their portfolios. Managers at TP&G have also used the research to earn outstanding returns for the firm's discretionary accounts. Which of the following statement is most likely correct?

• A. Johnny has not violated the Code and Standards.
• B. has violated the Code and Standards by using third-party research in discretionary accounts.
• C. has violated the Code and Standards by failing to disclose the referral agreement with Johnny.