Associated Administrators, LLC Fraud Policy

Background

The Company’s fraud policy is established to aid in the detection and prevention of fraud and other illegal acts against Associated’s clients, both Funds and Employer Plans, as well as against our Company. It is the intent of Associated to provide guidelines and assign responsibility for the development of controls and conduct of investigation to those within our Company who have oversite responsibility and to all employees.

Scope of Policy

This policy applies to any irregularity, or suspected irregularity, involving employees– as well as vendors, Fund participants, outside agencies doing business with employees, and/or other parties with a business relationship with the Company. Any investigative activity required will be conducted without regard to the suspected wrongdoer’s length of service, position/title, or relationship to the Company.

Policy

Management is responsible for the detection and prevention of fraud, misappropriations, and other irregularities and illegal acts. Fraud is defined as the intentional, false representation or concealment of a material fact for the purpose of inducing another to act upon it to his or her injury. Each member of the management team will be familiar with the types of improprieties that might occur within his or her area of responsibility, and be alert for any indication of irregularity.

An irregularity that is detected or suspected must be reported immediately to a member of the Executive Leadership Committee (“ELC”). ELC coordinates all investigations, both internal and external.

Actions Constituting Fraud

The terms defalcation, misappropriation, and other fiscal irregularities refer to, but are not limited to:

• – Any dishonest, fraudulent, or illegal act.
• – Misappropriation of funds, supplies, or other assets.
• – Impropriety in the handling or reporting of money or financial transactions.
• – Profiteering as a result of insider knowledge of company activities.
• – Disclosing confidential and proprietary information to outside parties.
• – Disclosing to other persons activities engaged in or contemplated by the company.
• – Accepting or seeking anything of material value from participants, vendors, or persons providing services/materials to the Company.
• – Destruction, removal, or inappropriate use of records, furniture, fixtures, and equipment; and/or
• – Fraudulent or corrupt acts which may include:
• System Issues – Where a process/system exists which is prone to abuse by either employees or public.
• Financial Issues – Where individuals or companies have fraudulently obtained money from the Company.
• Equipment Issues – Where the Company’s equipment is used for inappropriate personal use.
• Resource Issues – Where there is a misuse of resources, (e.g. theft of materials).
• Other Issues – Activities undertaken by officers of the Company which may be: unlawful; against the Company’s policies, below established standards or practices; or improper conduct.

Other Irregularities

Irregularities concerning an employee’s moral, ethical, or behavioral conduct should be resolved by the ELC and/or Human Resources. If there is any question as to whether an action constitutes fraud or illegal acts, contact the ELC for guidance.

Investigation Responsibilities

The ELC has the primary responsibility for the investigation of all suspected fraudulent acts as defined in the policy. If the investigation substantiates that fraudulent activities have occurred, the ELC will decide to prosecute or refer the results to the appropriate law enforcement and/or regulatory agencies or to Trustees, for independent investigation.

Confidentiality

The ELC treats all information received confidentially. Any employee who suspects dishonest or fraudulent activity will notify the ELC immediately, and should not attempt to personally conduct investigations or interviews/interrogations related to any suspected fraudulent act (see Reporting Procedure section below).Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. This is important in order to avoid damaging the reputations of persons suspected but subsequently found innocent of wrongful conduct and to protect the Company from potential civil liability.

Reporting Procedures

Great care must be taken in the investigation of suspected improprieties or irregularities so as to avoid mistaken accusations or alerting suspected individuals that an investigation is under way.Employees are often the first to realize that there is something wrong. However, they may not express their concerns because they feel that speaking up would be disloyal to their colleagues or to the Company. They may also fear harassment or retaliation. In these circumstances, it may be easier to ignore the concern rather than report what may just be a suspicion.

The Company’s Policy is intended to encourage and enable staff to raise serious concerns within the Company rather than overlooking a problem.

An investigation may be initiated by using the intranet on-line reporting tool (posters concerning Alertline are prominently displayed) or by phone or email to a member of the ELC.

An employee who discovers or suspects fraudulent activity will contact the ELC immediately. The employee or other complainant may remain anonymous. All inquiries concerning the activity under investigation from the suspected individual, his or her attorney or representative, or any other inquirer should be directed to the ELC. No information concerning the status of an investigation will be given out. Under no circumstances should any reference be made to “the allegation,” the crime,” “the fraud,” “the forgery,” “the misappropriation,” or any other specific reference.

The reporting individual should be informed of the following:

• – Do not contact the suspected individual in an effort to determine facts or demand restitution.
• – Do not discuss the case, facts, suspicions, or allegations with anyone unless specifically asked to do so by the ELC.

Termination

If an investigation results in a recommendation to terminate an individual, the recommendation will be reviewed for approval by the designated representatives from Human Resources. Should the ELC believe any member of the ELC may be involved in the fraudulent activity, whether as perpetrator or in collusion, that individual shall be removed from the investigation, which will be conducted by the remaining members.

Administration

The ELC is responsible for the administration, revision, interpretation, and application of this policy. The policy will be reviewed annually and revised as needed.