RubinBrown Team Member Manual

Section: Handling Potential Client Irregularities and Notification Of Third-Party Invest 909 Ethics and Business Conduct

Policy Title: Policy Number:

Effective Date:

Supersedes Policy Dated:

06/01/2024

06/01/2023

Background: RubinBrown has identified procedures for handling client irregularities and notification of third-party investigations for client engagements. Policy: All team members are expected to comply with the procedures outlined below for handling potential client irregularities and notification of third-party investigations for client engagements. Failure to comply with these procedures may result in disciplinary action, up to and including termination of employment. Procedure: When made aware of potential client irregularities or third-party investigations involving the Firm or Team Members related to client engagements, the following procedures shall be performed. This policy does not apply to routine reviews of our work papers by successor professional services firms covered under existing RubinBrown policies: 1. The Primary Partner shall immediately inform the Chair of the Risk Management Committee, the Office Managing Partner and the Office and Firm Service Unit Leader of the matter. 2. The Chair of the Risk Management Committee, with the help of the Primary Partner, shall locate and sequester all relevant work papers, including those stored off-site. In addition, the Chair of the Risk Management Committee will notify the technology services department of the need to make copies of electronic files, engagement binders and mail files. 3. No changes shall be made to the work papers, including both electronic and hard copy work papers. The only acceptable alteration to the work papers shall be in the form of a supplementary memo placed in the work papers along with any applicable attachments. Any such memo must be signed and currently dated by the Primary Partner, Service Unit Leader and the Chair of the Risk Management Committee. 4. Under no circumstances should any materials (emails, notes, draft memos, etc.) be deleted or destroyed. 5. The Service Unit Leader will arrange for an independent review of the work papers by an appropriate Team Member for the purpose of understanding the work performed and conclusions reached by the engagement team. 6. The Managing Partner and/or Chairman shall approve all decisions regarding the retention of legal counsel on behalf of the Firm. 7. Only the Managing Partner and/or Chairman shall comment to the press. Any press inquiries shall be referred to the Managing Partner. If confronted, the only acceptable comment to the press by a Team Member is “we make no comments regarding client matters”. 8. Any and all written correspondence with third parties related to such matters shall first be discussed with the Chair of the Risk Management Committee before issuance. 9. The Chair of the Risk Management Committee shall keep the Primary Partner , Service Unit Leader and Managing Partner informed of any and all developments related to the matter. 10. It is preferred that any oral communications with third parties take place with at least two Team Members present. Team Members shall maintain detailed contemporaneous notes related to any discussions held with third parties related to the matter. 11. All internal communications shall be limited to face-to-face discussions, if at all possible. Email shall not be used. 12. Access to our work papers shall be granted only after obtaining the appropriate written client approvals and any applicable waivers from those requesting access, after discussion with legal counsel. 13. The Managing Partner and/or Chairman shall approve any deviations from this policy.

RUBINBROWN TEAM MEMBER MANUAL | 92