ÓÐÁϺÐ×ÓAPP

• Driven by accountable leadership and supported across the firm
  Our Board of Directors (through the Audit Committee) and the Chief Ethics & Compliance Officer, supported by leadership at all levels, oversee and are accountable for our commitment to compliance and ethical conduct and the Ethics & Compliance program. This includes providing effective tone-at-the-top messaging and adequate resources. The Chief Ethics and Compliance Officer reports to and educates the Audit Committee in person twice annually and additionally as needed on our key compliance areas and initiatives, including risk assessment and audit findings.
  
  
• Informed through regular risk assessments
  Ethics & Compliance coordinates with our enterprise risk management and business teams to proactively identify new compliance risks and conduct comprehensive risk assessments and benchmarking exercises regularly for our key and emerging compliance risk areas. This enables us to identify requirements and risk, determine whether the program is designed to address these requirements and risks, and assess whether the program is operating as designed. Risks identified during these assessments are addressed through tailored program enhancements.
  
  
• Enabled by standards, controls, tools, and technology
  We establish clear, specific, and documented codes (including our Code of Business Ethics and Conduct), policies, procedures, and controls for directing employee behavior. We promote, enable, and strengthen compliance with laws, regulations, and company standards. Using new and better tools and technology grounded in existing business processes—such as recruiting and hiring, bidding for work, onboarding suppliers—we operationalize compliance systems and provide employees with resources.
  
  
• Engagement through training and awareness
  We empower our employees to identify, escalate, and mitigate risks through a mix of firmwide and targeted audience training and awareness. We rely heavily on real-world scenarios and regularly adjust our approach based on participant feedback and industry best practices.
  
  
• Routinely monitored and audited to ensure appropriate response
  We conduct regular compliance monitoring activities to systematically evaluate our programs, monitor trends, and provide independent review to ensure appropriate programmatic and specific response.

All ÓÐÁϺÐ×ÓAPP employees are required to report legal or ethical concerns through established firm reporting channels. When notified of a concern, the firm follows our detailed investigative protocols to investigate each allegation of misconduct fully and fairly and assesses and imposes discipline for misconduct. Where appropriate, the firm discloses misconduct to regulatory authorities and escalates issues to senior leadership and the Board of Directors.

One of the available reporting channels is the , which:

• Provides phone and web intake options for employees to both ask Ethics & Compliance related questions and report unethical behavior
• Is available 24 hours a day, 7 days a week
• Gives employees the option to report illegal or unethical behavior anonymously