RubinBrown Team Member Manual

Whistleblower Policy 908

Policy Title: Policy Number:

Section:

Ethics and Business Conduct

Effective Date:

Supersedes Policy Dated:

10/15/2024

06/01/2024

Background : RubinBrown has implemented a confidential means of reporting suspected wrongful conduct such as discrimination, harassment, potential noncompliance with applicable professional and legal requirements and with the Firm’s policies and procedures or other alleged irregularities, referred to as the "Whistleblower Policy." This policy ensures a safe and confidential environment to report misconduct for: • Team Members; • Other Participants (accounting firms, accountants, and other professionals or organizations, whose responsibilities include assisting with the performance of the Firm’s engagements; or the design, implementation, or operation of the Firm’s QC system, including engagement quality reviews); • Clients or third parties. Collectively all of these groups are considered Covered Individuals. The policy is intended to encourage transparency and accountability within the Firm. Policy Overview : The Whistleblower Policy offers a confidential means of submitting concerns, with the option to remain anonymous, through a secure website. Reports will be directed to the Chair of Risk Management, Managing Partner and Chairman of the Board. This policy aims to protect Covered Individuals who, in good faith, disclose suspected wrongful conduct. The policy fosters an atmosphere where Covered Individuals are encouraged to meet their obligations to disclose client-related matters, internal issues, legal violations, or serious breaches of conduct, as outlined by the Firm's policies without fear of retaliation. Processes and Responsibilities for Receiving Complaints : The Firm has established and maintains processes for receiving complaints and allegations from Covered Individuals. These processes include: • A confidential whistleblower website for anonymous submissions by Covered Individuals, which will ensure concerns are reported directly to the Chair of Risk Management, Managing Partner and Chairman of the Board. • Designated personnel responsible for managing and monitoring the intake and acknowledgment of complaints. • Protection from Retaliation : The Firm strictly prohibits retaliation against Covered Individuals who make complaints in good faith. This includes any form of harassment, demotion, or punitive action. Anti-Retaliation Safeguards : • A structured process to protect whistleblowers from retaliation. • Clear communication of the Firm’s zero-tolerance policy for any retaliatory actions. • Appropriate disciplinary measures for any Team Members found retaliating against whistleblowers.

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