ICMARC Associate Handbook August 2016

P P Having a social media profile or posting to other social media that disclose any trade secrets, insider information, or other confidential or proprietary information of ICMA-RC or related entities, including participant information, or violate any privacy policies of the corporation P P Having a social media profile or posting to other social media that violate any of the terms of any confidentiality of information policy maintained by the corporation or its related entities or the ICMA-RC Code of Ethics Associate social media profiles or postings to other social media may not contain any content that: P P Violates any laws, including laws pertaining to intellectual property P P Reveals any employer or participant information P P Contains content that is defamatory or libelous or might reasonably be construed as harassment or disparagement on the basis of race, color, religion, national origin, sex, age, marital status, personal appearance, sexual orientation, gender identity or expression, family responsibilities, genetic information, matriculation, political affiliation, physical or mental disability, or veteran status, or P P Violates any policies, rules, standards, or requirements applicable to the corporation or its related entities. The following are permitted only with the express prior written permission of the President and Chief Executive Officer and/or the SVP, Chief Operating Officer: P P Having a social media profile or posting to other social media that imply ICMA-RC sponsorship or support by the corporation P P Having a social media profile or posting to other social media that use ICMA-RC time, facilities, resources, or supplies P P Having a social media profile or posting to other social media that use any logos or trademarks of ICMA- RC or related entities for any business, commercial or anti-competitive purpose P P Having a social media profile or posting to other social media to represent ICMA-RC and/or discuss financial topics because of the requirements of FINRA Notice 10-06 to covered communications. If such approval is obtained, the following guidelines must be followed: – – Suitability rules apply to recommendations made through blogs or social media sites and any recommendations must be approved by Compliance in advance – – Static postings to blogs that are not interactive also require approval by Compliance in advance – – Any postings to third party sites that reasonably might be construed as investment related must be saved and promptly submitted to Compliance for supervisory and archiving purposes. Any such postings must, of course, also comply with the provisions of this Blogging Policy. P P FINRA licensed associates must inform Compliance and the SVP, Chief Operating Officer of any blogs or social networking sites that you maintain or in which you participate that implicate the corporation, the duties the associate performs for the corporation, or any obligations the associate or ICMA-RC has under FINRA. For any questions regarding the application of FINRA Regulatory Notice 10-06 concerning postings to Social Media Web Sites, see ICMA-RC’s Social Media and Networking Policy or ask Compliance for guidance in advance of any postings. It is the responsibility of every FINRA licensed associate to comply with FINRA Regulatory Notice 10-06. If you have a blog or social media profile that refers to ICMA-RC, its related entities or their operations, personnel, products or services, you must notify your manager and the Legal Division of the existence of the blog or social media profile and include a statement in the blog or social media profile that all views expressed in connection with ICMA-RC and related entities are yours and have not been reviewed or approved by the corporation.

Confidential — for Internal Use Only

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