RubinBrown Team Member Manual

POLICY CONTINUED Policy Title: Policy Number:

Whistleblower Policy 908

Section:

Ethics and Business Conduct

Investigation and Addressing of Complaints : Upon receiving a complaint or allegation, the Firm will initiate an investigation proportionate to the significance of the complaint: • Nature, Timing, and Extent : • Complaints will be investigated promptly and confidentially. The investigation process will be directed by Chair of Risk Management, Managing Partner and Chairman of the Board. • The status of each complaint will be reported monthly to the Board of Directors. • Investigations will involve internal or external individuals depending on the complexity of the issue. • Action Plans : • Findings will be documented and corrective actions implemented. • Systemic issues identified through investigations will be addressed for future prevention. Review and Monitoring : The whistleblower policy will be regularly reviewed to ensure it meets legal standards and internal guidelines. Periodically, the Chief Information Officer will submit a “test complaint” to the system to ensure notifications are being made as intended. Communication and Training : Firm personnel will be trained regularly on the whistleblower policy, including their rights

and responsibilities, and how to report noncompliance. Team members may access the Whistleblower Hotline here: https://report.syntrio.com/_StandardCustomURL/LHILandingPage.asp

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