RubinBrown Team Member Manual

Section: Acceptance of Gifts and Fees 903

Policy Title: Policy Number:

Ethics and Business Conduct

Effective Date:

Supersedes Policy Dated:

06/01/2024

06/01/2023

Background: It is the policy of RubinBrown to discourage team members from accepting gifts or hospitality from clients and suppliers to avoid potential conflicts of interest. Policy: Recognizing the need for some flexibility in dealing with this general rule, the only exception is where the cost of a gift is less than $200 in retail value. It is understood that the gift is offered for reasons of personal esteem and affection during the holiday season or other special occasion and not with the intent to influence the team member in the conduct of RubinBrown business. Conventional hospitality (e.g. lunch or dinner meeting, etc.) is acceptable when the frequency and total cost of hospitality is reasonable and would not be construed by an impartial observer as affecting the team member's judgement regarding the work for which the firm is employed. Hospitality where the value exceeds $200 should be referred to the team member's Service Unit Leader and Office Managing Partner for approval prior to acceptance. The acceptance of fees or commissions by any team member in connection with Firm business is strictly prohibited. Honorariums and fees for conducting continuing education programs or speaking engagements must be given to the Firm. Procedure: All gifts from clients, suppliers and any offer of a personal fee or commission in connection with RubinBrown business should be reported immediately to the team member's Service Unit Leader or department leader. The department leader shall, in their discretion, either direct the team member to return the gift or contribute it to an approved charity as RubinBrown directs if the acceptance of the gift would be a conflict with the requirements of this Policy. Any gift or hospitality of $200 or more, which for practical reasons cannot be returned, shall be donated to the Firm or given to charity and a memo to such effect will be forwarded to Human Resources for inclusion in the team member's file.

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