Failure to comply with paragraph 3.2.1 of the Code of Ethics – offering and/or making a loan to a purchaser of a first-hand property 2. Breach of section 15 of the Practice Regulation – failure to establish proper procedures or systems to supervise and manage its business of doing estate agency work to ensure that its employee complied with the provisions of the EAO - its employee offered and/or made a loan to a purchaser of a first-hand property