RubinBrown Team Member Manual

Section: Anti-Bribery and Corruption Policy 906

Policy Title: Policy Number:

Ethics and Business Conduct

Effective Date:

Supersedes Policy Dated:

06/01/2024

06/01/2023

RubinBrown LLP, its subsidiaries and affiliates (collectively, “RubinBrown”), is committed to conducting business in accordance with all applicable laws, rules and regulations and in particular the US Foreign Corrupt Practices Act of 1977, as amended (the “FCPA”) at the highest ethical standards. As part of this commitment, all forms of bribery and corruption are unacceptable and will not be tolerated. We must not, and we must ensure that any third party acting our behalf does not, act corruptly in our dealings with clients or in anyone else. This policy applies to all RubinBrown team members (full and part-time), including temporary/seasonal team members, regardless of job title and responsibilities or location. All RubinBrown team members are expected to comply with this policy regardless of whether local law or practices might permit something to the contrary. Bribery is when financial or other advantages are offered, given or promised or agreed to be received with the intention to induce or reward them or another person to perform their responsibilities improperly. Bribes may be given directly or through a third party and may benefit another recipient other than the person accepting the bribe. Bribes include but are not limited to money, unreasonable gifts, entertainment or hospitality, kickbacks, unwarranted allowances or expenses, charitable contributions, etc. As such, no director, officer, employee, agent, contractor or consultant of RubinBrown shall, directly or indirectly give, offer or agree to give or offer a payment, loan, reward, advantage or benefit of any kind to a public official, entity, or to any person, whether public or private: (a) as consideration for an act or omission by the public official in connection with the performance of his/her duties; (b) to induce the public official to use his/her position to influence any acts or decisions of the government for which the official performs his/her duties; or (c) to obtain or retain business, direct business to any person, receive an improper advantage. Procedure: RubinBrown will not tolerate any act of bribery or corruption. This includes if the bribe is promised but does not actual take place. Gifts or receiving gifts of hospitality may occur when reasonable as outlined under the policy titled Acceptance of Gifts and Fees (Policy 903). RubinBrown team members are required to obtain 2 hours of Ethics training annually with various options provided on how to obtain this training (e.g. on-line course, seminar, in-person lecture, etc.) RubinBrown maintains a system of financial and other internal controls and procedures designed to detect and prevent violations of the FCPA and other anti-bribery laws. All payments must be clearly and accurately reflected in the financial records and reports of RubinBrown. All employees are responsible for following RubinBrown’s procedures for carrying out and reporting business transactions, including receipt of appropriate authorizations and following internal auditing controls. RubinBrown employees must maintain accurate records of all transactions and particularly those which relate in any way, directly or indirectly, to government officials. All third parties working on behalf of RubinBrown must be aware of this policy. RubinBrown will not engage with any third party known or under reasonable suspect of engaging in bribery. All team members have an obligation to act with integrity and to ensure we, as a firm and as individuals, are complying with the policy. Team members should raise concerns regarding anti-bribery and corruption to their Service Unit Leader or Office Managing Partner. If a team member is uncomfortable going these individuals, they may report their concerns through the firm's confidential reporting hotline at https://www.intouchwebsite.com/index.asp?Lid=1&Cid=70398. A breach of bribery laws can result in fines for both the firm and the individual involved and may also result in legal action or imprisonment. RubinBrown reserves the right to take disciplinary action (including termination or legal action) against any individual(s) violating this policy. From time to time, RubinBrown personnel may be required to complete additional FCPA training and sign a certification acknowledging commitment to, full understanding of, and compliance with this Policy. The acknowledgment statement shall be included in the personnel file of each such employee.

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