ICMARC Associate Handbook August 2016

Reporting As part of our Whistleblower Policy, ICMA‑RC has established a toll-free hotline — 888-261-1499 — and a website, www.ethicspoint.com , where you can report any violation or suspected violation of the Code of Ethics or Standards for Conduct to an independent agency designed to receive anonymous or other reports.

Violations Code of Ethics violations include, but are not necessarily limited to, the following:

FINANCIAL AND ACCOUNTING MATTERS P P Conduct or actions that constitute fraud or intentional misrepresentation in the preparation/evaluation, review or audit of accounting or financial statements of ICMA‑RC P P Conduct or actions that constitute fraud or intentional misrepresentation in the recording and maintaining of accounting or financial records of ICMA‑RC P P Non-compliance or material deficiencies in connection with ICMA‑RC’s internal accounting controls P P Conduct or actions that constitute a misrepresentation or false statements to or by an officer, senior management, or other associate or accountant regarding a matter contained in the financial records, financial reports or audit reports of ICMA‑RC LEGAL AND REGULATORY MATTERS P P Conduct or actions that violate local, state or federal law applicable to ICMA‑RC P P Conduct or actions that constitute a violation or suspected violation of the standards set forth by the Financial Industry Regulatory Authority (FINRA) OTHER CODE OF ETHICS MATTERS P P Conduct or actions that breach the requirements of confidentiality with respect to ICMA‑RC confidential information, “nonpublic” information regarding ICMA‑RC “customers” and “consumers” (as such terms are defined in the Securities Exchange Act of 1934 Regulation S-P), portfolio holdings, use of computer systems or intellectual property, or other confidentiality requirements P P Conduct or actions that in fact or appear to violate the ICMA‑RC conflict of interest policy P P Conduct or actions that violate the policy relating to outside business or employment activities P P Conduct or actions that violate the policy with respect to gifts and business entertainment P P Conduct or actions that violate the policy on political activities and contributions P P Conduct or actions that violate or appear to violate either the letter or the spirit of ICMA‑RC’s Code of Ethics P P Issues related to the ICMA‑RC Standards for Conduct Retaliation ICMA‑RC associates will not be subject to discipline or any form of retaliation for reporting, in good faith, a violation or a suspected violation of the Code of Ethics, Standards for Conduct, or for participating in or cooperating with an investigation into such conduct. Associates are expected to cooperate fully with any inquiry or investigation by ICMA‑RC regarding an alleged violation of the Code of Ethics, and failure to do so may result in disciplinary action up to and including termination of employment.

Confidential — for Internal Use Only

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