ICMARC Associate Handbook August 2016

Confidential — for Internal Use Only

Associate Handbook August 2016 |

ICMA‑RC prohibits associates from making bad faith allegations of discrimination or harassment. Associates

found to have engaged in this type of behavior may be subjected to disciplinary action up to and including

termination of employment. Because of the serious nature of these matters, bad faith reports are exempt from

the protection under this policy.

Questions?

A copy of the

is distributed to associates each year. If you have questions regarding this policy,

you can contact the ICMA‑RC Compliance Department, Human Resources or the toll-free Whistleblower Hotline, 888-261-1499.

You can also contact

ICMA-RC CONFIDENTIALITY AND THE PRESS

Because of the regulations affecting ICMA-RC as a regulated entity in the financial services industry, it is

important for ICMA-RC to respond to media inquiries only through designated representatives. Unless

expressly authorized by the President and Chief Executive Officer (CEO) and/or the SVP, Chief Operating

Officer, no ICMA-RC associate should speak with the press as an ICMA-RC representative, or convey any

information regarding ICMA-RC, VTC, VIA, ICMA-RC Services and/or The Vantagepoint Funds or any

subsidiary or affiliate to any member of the press. This includes confirming or denying any statement made to

you by another party. Any associates who are contacted by a member of the press seeking ICMA-RC’s position

on such matters should immediately refer the inquiry to the SVP, Chief Operating Officer, who will address it

and oversee the approval process, as appropriate.

In addition, ICMA-RC associates are not allowed to contribute to any materials on behalf of a vendor

including, but not limited to, press releases, endorsements or references provided verbally or in writing. Any

inquiries or requests of this nature should be immediately directed to the SVP, Chief Operating Officer.

A breach of this policy will result in disciplinary action up to and including termination.

Social Media Policies

ICMA-RC understands that some associates will access or use Social Media, Internet blogs, public forums,

Twitter‑type formats, social networking sites and similar venues (collectively called “social media”) because of the

interchange of ideas and information they can promote. At the same time, the corporation’s legitimate interests and

those of other associates can, in some circumstances, be compromised by the inappropriate uses of these media.

Accordingly, the following restrictions apply, even when you are on your own time and using your own

computer equipment or communication devices.

The following are never permitted:

Having a social media profile or posting to other social media that adversely affect the interests or

reputation of the clients or participants of ICMA-RC and related entities

Having a social media profile or posting to other social media the fact that an associate works for ICMA-RC

if that blog, site or posting might reasonably be construed as having sexual or violent content or implications

Having a social media profile or posting to other social media that support a competitor of ICMA-RC or

its related entities or otherwise conflict with an associate’s duties to the corporation