RubinBrown Team Member Manual

Insider Trading Policy 1214

Policy Title: Policy Number:

Section:

Risk Management

Effective Date:

Supersedes Policy Dated:

06/01/2024

06/01/2023

Policy: RubinBrown's policy prohibits any partner or team member from acting upon, misusing, or disclosing any material non-public information, known as inside information. Any instances or questions regarding possible inside information must be immediately brought to the attention of the appropriate Risk Management representative or Service Unit Leader, and any violations of the Firm’s policy may result in disciplinary action and/or termination. Note that this policy does not apply to RubinBrown Advisors, which have their own insider trading policies. The Firm's policies include as follows: 1. A partner or team member of RubinBrown or its affiliates shall not buy or sell securities for his or her personal portfolio(s) where his or her decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. 2. A partner or team member of RubinBrown or its affiliates shall not disclose material non-public information that is derived, in whole or in part, by reason of his or her employment to individuals who are not involved with the engagement to which the information pertains or individuals outside of the firm unless the information is also available to the investing public on reasonable inquiry. 3. This Insider Trading Policy is distributed to new partners and team members upon hire. 4. The Risk Management Committee partners and Service Unit Leaders may provide guidance to partners and team members on any possible insider trading situation or question. 5. RubinBrown’s Insider Trading Policy is reviewed and evaluated on a periodic basis by the Risk Management Committee and updated as may be appropriate. 6. The Chair of the Risk Management Committee shall prepare a written report to the Managing Partner and/or the Firm’s legal counsel of any possible violation of the Firm ’ s Insider Trading Policy for use in implementing corrective and/or disciplinary action.

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