ICMARC 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 ICMA‑RC Whistleblower Policy 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 www.ethicspoint.com . 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: P P 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

P P 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 P P 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

Confidential — for Internal Use Only

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