ICMARC Associate Handbook August 2016

with all aspects of ICMA‑RC’s business, and it outlines procedures that address questions relating to the Code of Ethics, federal securities laws and other regulatory requirements. It also summarizes appropriate disciplinary actions for violations. A significant issue addressed in the Code of Ethics is confidentiality. Like most successful corporations, ICMA‑RC develops distinctive ways to design, produce and market its products and services. You are not permitted to reveal this confidential information to sources outside the corporation. Furthermore, any system, system design, program, product or information used by or unique to ICMA‑RC must not be used for personal gain or revealed to persons outside of the corporation, either during or after your employment with ICMA‑RC. This policy does not bar any protected concerted communications permitted under the National Labor Relations Act or any other law. Under regulations pertaining to insider trading, an associate who acquires non-public information about an issuer of securities is prohibited from communicating that information or taking investment actions based on such information. ICMA‑RC associates must not participate in activities that may present a conflict of interest such as engaging in outside employment and business activities, giving or receiving gifts or business entertainment, becoming a candidate for an elective office or making political contributions to state or local government officials. ICMA‑RC associates must also consider employment with ICMA‑RC their primary employment responsibility. Certain activities may present a conflict of interest, and therefore, you are required to obtain prior written approval from the ICMA‑RC Compliance Department and, in certain instances, your manager before engaging in certain outside business ventures. The Code of Ethics provides guidelines for the types of outside business or employment activities for which you must receive prior approval. The Code of Ethics also encompasses the Personal Securities Trading Policy, which requires that certain associates who are deemed to be Access Persons pre-clear securities transactions and stipulates a blackout period for trading in securities that have been traded by ICMA‑RC or any of its affiliated portfolios. Access Persons are also required to submit quarterly and annual reports of covered securities transactions, holdings and accounts. The ICMA‑RC Compliance Department will notify you if you are deemed to be an Access Person and will provide training on the pre-clearance, blackout period, and quarterly or annual reporting requirements. Each year, you will receive a copy of the Code of Ethics, Personal Securities Trading Policy and the corporation’s Whistleblower Policy along with an acknowledgment form to certify that you have received, read, and understand the policies. If you have any questions regarding these policies, please contact the ICMA‑RC Compliance Department or Human Resources. WHISTLEBLOWER POLICY ICMA‑RC associates, by virtue of their employment, have a responsibility to report what they deem to be violations of the ICMA‑RC Code of Ethics and to comply with the standards outlined in this Code. If you know or reasonably believe that any other associate or representative of ICMA‑RC has engaged or is engaging in activity that violates applicable law or our Code of Ethics, we request that you report that to your supervisor, the Chief Compliance Officer, the head of Human Resources, or to a confidential hotline as explained in the following paragraph. You can report such conduct either openly or anonymously.

Confidential — for Internal Use Only

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