RubinBrown Team Member Manual

POLICY CONTINUED Policy Title: Policy Number:

Section: Anti-Bribery and Corruption Policy 906

Ethics and Business Conduct

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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