Document information and change log

Document Information

Change log

Gender And Entity Neutrality

The masculine form is used solely for the sake of better readability. It always refers to persons of any gender identity (m/f/diverse). This document uses the abbreviation “Give” for all legal entities and subsidiaries.

Table of Contents

Introduction        4

Scope        4

Purpose        4

Recruitment and Hiring        4

Job Postings and Descriptions        4

Interview Process and Guidelines        5

Background Check Procedure        5

Steps to Initiate the Background Check:        5

Internal Background Checklist        5

Documentation        6

The CFBO will maintain detailed records of the background check process, including findings from both internal and third-party reviews.        6

Candidate Communication and Notifications        6

Documentation Preparation and Distribution        6

Confidentiality Agreements        7

Process:        7

Onboarding        7

IT Onboarding Notification        7

IT Onboarding Process        7

BYOD Operating Systems        8

New Joiner Organizational Documentation        8

New Joiner Training        8

Active Employee roster        9

Payroll Onboarding Process        9

New Joiner Periodical Check-Ins and bi-annual Review Process        10

New Joiner Periodical Check-Ins and Annual Review Process        10

Employee Evaluation        10

Self-Assessment and Evaluation Review Process        10

Access Control and Confidentiality        11

Employee Complaint        11

Roles and Responsibilities        12

Employees        12

Managers and Supervisors        12

The Compliance Team        12

Steps in the Complaint Process        12

Step 1: Submission of Complaint        12

Step 2: Acknowledgment and Initial Review        12

Step 3: Investigation        12

Step 4: Resolution and Outcome        13

Step 5: Appeals Process        13

Confidentiality and Protection        13

Training and Awareness        14

Monitoring and Continuous Improvement        14

Offboarding        14

Organization-Initiated Termination        14

Leave Notice and Stakeholder Notification        14

Termination Paperwork        15

Handover Documentation        15

External Communication to Clients        16

Exit Interview        16

Access Removal and Contact Information Collection        16

Final Payments        16

Update Organizational Chart        17

Bring Your Own Device (BYOD)        17

Conflict Resolution        18

Policies and Procedures        18

Give Corporation Core Teams Overview        20

Introduction

Scope

This policy applies to all employees, contractors, and stakeholders of Give Corporation, regardless of their position, department, or location. It encompasses all stages of the employment lifecycle, including recruitment, hiring, onboarding, performance management, and offboarding, as well as any third-party engagements or contractor relationships. This policy also includes procedures for managing personal device usage (BYOD), data security, compliance with internal policies, and adherence to industry standards, and other regulatory frameworks.

Purpose

The purpose of this policy is to provide a comprehensive framework for managing employee and contractor engagements, ensuring consistent, fair, and transparent practices throughout all stages of the employment relationship. It aims to outline clear procedures for recruitment, onboarding, training, performance management, and offboarding, while also addressing compliance requirements, data security, and confidentiality. This policy is designed to establish a structured approach to internal processes, maintain regulatory compliance, safeguard company data, and create an inclusive and supportive work environment that aligns with Give Corporation’s values and objectives.

Recruitment and Hiring

Job Postings and Descriptions

When there is a need to hire a new employee, the Department Lead is responsible for preparing a detailed job description. This description must clearly outline the role's responsibilities, required qualifications, experience, skills, and any other essential criteria. It should also include information on how to apply, including the email address or online platform where candidates should send their CVs. The job description should be crafted professionally, using inclusive and respectful language that aligns with diversity and equality standards, ensuring that the role appeals to a broad range of candidates.

Once the job description is finalized, the Sales Team will take charge of posting the vacancy on the company website, job boards, LinkedIn, and any other relevant hiring platforms. The Sales Team should monitor all applications and promptly forward them to the hiring department to ensure timely processing and review.

Interview Process and Guidelines

The interview process should be conducted in a manner that is fair, respectful, and in line with the company’s values. Each interview should aim to assess the candidate's qualifications, skills, and cultural fit in a non-discriminatory manner. The Hiring Department Lead will determine the number of interview rounds required, which may vary based on the complexity and seniority of the role.

Interviewers must treat all candidates with respect, providing a welcoming environment where candidates feel comfortable and valued. It is essential to ensure consistency in the questions asked and the evaluation criteria applied to maintain a fair and objective selection process.

Background Check Procedure

If a candidate meets the job role criteria and the Department Lead or co-founders decide to proceed with the hiring process, the Compliance or HR Lead will conduct a background check to verify the candidate’s identity, qualifications, and suitability for the role.

Steps to Initiate the Background Check:

1. KYE Form Submission
   The Hiring Manager or Compliance Team  will send the "Know Your Employee" (KYE) form to the candidate, along with a request for the following:

• A valid identification document
• A LinkedIn profile link (or an updated resume if LinkedIn is not available)

2. Form Completion and Return
   The candidate must complete the KYE form and provide the requested documents to HR/Compliance Team.
3. Background Check Process
   Upon receiving the completed KYE form and supporting documents, the HR/Compliance Team will initiate a background check, which may involve:

• Google-based Open-Source Review
• Sanctions and Watchlist Search (OFAC, PEP, Negative News Search)
• Social Media Review (LinkedIn, GitHub, or relevant platforms)
• Identity and Qualification Verification

Where relevant (for positions involving system access or financial responsibilities), an enhanced background check may be performed, including additional criminal or adverse media screening.

Internal Background Checklist

The CFBO will use the Background Checklist Template to ensure a consistent and comprehensive review. This checklist includes:

The Compliance Team or HR Lead will use the Simplified Background Checklist Template to ensure a consistent and complete review.
This checklist includes the following sections:

• Identity and Qualification Verification:
  Confirm the candidate’s identity and ensure that the experience and qualifications listed in the LinkedIn profile or resume align with the job description.
• Open-Source Search (Google):
  Conduct a Google search for the candidate’s name, location, and relevant keywords to identify any criminal, extremist, or reputational red flags (e.g., fraud, hate speech, unethical conduct).
• Sanctions and Watchlists (OFAC / PEP / Negative News Search):
  Verify that the candidate is not listed on any restricted or sanctioned lists.
• Social Media Profiles:
  Review publicly available social media and professional accounts to identify any behavior that may negatively affect the company’s reputation.
• Criminal Record Check (optional):
  For roles involving access to production systems, financial data, or confidential information, perform an additional criminal background check through open-source search or authorized registry access.

Documentation

The Compliance Team or HR Lead will maintain detailed records of the background check process, including findings from both internal and third-party reviews.

Role-Based Approach

• The Standard Background Check applies to all employees and contractors.
• The Enhanced Background Check (EBC) applies to roles with elevated risk or access (e.g., finance, compliance, or system administration) and includes deeper criminal/adverse-media screening.
• Any red flags discovered will be reviewed jointly by the Compliance Lead and Hiring Manager before proceeding with employment.

Access Controls and Secure Storage

All documentation related to background checks will be securely stored and accessible only to authorized personnel, including the Finance Department, Compliance Department and Co-founders.

Candidate Communication and Notifications

Due to the potentially high number of applications, the company is not obligated to notify every applicant regarding the status of their application. Only candidates who proceed to the interview stage will receive further communication. Following the interviews, the Department Lead or another authorized representative is responsible for notifying candidates about the outcome. This includes providing an offer letter to successful candidates or a respectful and polite rejection notice to those who were not selected.

Documentation Preparation and Distribution

After the co-founders finalize the payment compensation, the CFBO drafts and sends the agreement to the new joiner, detailing invoicing and payment terms. For contractors engaged through BPOs, compensation arrangements are managed directly with the BPO, and the principal company remains uninvolved.

Once the new joiner returns the signed agreement, the CFBO ensures it is complete and accurate.

Access Control

Agreements are strictly accessible to the Finance Department and co-founders.

Confidentiality Agreements

The CFBO must inform the Compliance Manager whenever there is a new joiner at Give. The Compliance Manager is responsible for completing the onboarding template with the new joiner’s information and managing the Confidentiality Agreement process.

Process:

1. Notification
   The CFBO notifies the Compliance Manager through the Slack hr-onboarding-and-termination channel.
2. Confidentiality Agreement Preparation
   The Compliance Manager prepares the Confidentiality Agreement using the approved template.
3. Agreement Distribution
   The Compliance Manager sends the Confidentiality Agreement to the new joiner for review and signature.
4. Verification
   Once the signed Confidentiality Agreement is received, the Compliance Manager verifies that it is complete and correctly signed.
5. Secure Upload
   The Compliance Manager uploads the finalized Confidentiality Agreement to the company’s secure Google Drive folder, ensuring appropriate access restrictions are in place.
6. Clarifications
   If the new joiner has questions or requires clarification, the Compliance Manager consults with the Compliance Team, CFBO, or co-founders as necessary. After resolving the queries, the Compliance Manager provides a clear response to the new joiner.

Onboarding

IT Onboarding Notification

1. After document verification and upload, the CFBO sends a notification to the IT Director via the Slack hr-onboarding-and-termination channel, confirming that the new joiner needs to be onboarded.

IT Onboarding Process

IT Director Responsibilities:

1. The IT Director prepares a New User Form for general onboarding. This includes:

• Issuing a company email address.
• Issuing a Slack access (if applicable)
• Providing system access according to the new joiner’s role.

2. If necessary, the IT Director prepares a separate New User Form for accessing the Give Payments Production Portal https://portal.givepayments.com, aligned with the new joiner’s role.
3. For any clarification on the required system or environment access, the IT Director must coordinate with the respective Department Lead.

BYOD Operating Systems

Ensure new team members' devices comply with BYOD standards by promptly updating the operating system list and gathering antivirus evidence.

Responsibilities:

• IT Director:

• Onboarding: Update the BYOD operating system list immediately when a new team member joins.
• Antivirus Evidence: Collect and verify current antivirus evidence from the new device(s).
• Annual Check: Conduct an annual review of the operating system list and antivirus evidence.

• Compliance Team:

• Audits: The Compliance Team will request the annual review when it needs to be done.

At any time, or as part of the scheduled audit, the Compliance Team may request the updated BYOD operating system list and antivirus evidence.

New Joiner Organizational Documentation

On the new joiner’s first day, Compliance Manager sends a welcome email/ Slack message that includes the following documents and instructions:

• A company overview and organizational structure.
• An employee handbook detailing company policies, procedures, and the code of conduct.
• A link to Google Drive with all policies.

New Joiner Training

Additionally, Compliance Manager sends request to New Joiner to complete the required training or review policies within 5 working days, including:

• New Joiner Training, incl. BSA/OFAC Training
• Security Awareness Training, including Incident Response training
• Privacy Awareness Training
• Sign IT Security Policy Acknowledgment Form

Upon completion of the training, Compliance Manager must collect the Confirmation of Participation:

• If the training includes a quiz, the Confirmation of Participation is collected automatically through a form.
• For training without quizzes, the Compliance Manager must request confirmation via email or receive signed training confirmation through DocuSign.

Compliance Manager is responsible for maintaining all training confirmations.

Confirmation of Participation and related new hire paperwork must be uploaded to the designated storage location.

Access Controls: Access to the Confirmation of Participation is restricted to the Compliance team, Finance Department and co-founders.

Active Employee roster

To ensure that the organization maintains accurate and current records of all employees, the Active Employee Roster must be updated immediately upon the addition of any new team member.

Roster Update Responsibility

The Compliance Manager is responsible for promptly updating the Active Employee Roster with the new hire’s details.

The Compliance Manager will coordinate with HR and other relevant departments (e.g., IT, Payroll) to ensure that the roster accurately reflects the new employee’s information.

Compliance

Regular audits will be conducted to verify the accuracy of the Active Employee Roster.

Payroll Onboarding Process

After completing the document verification and onboarding process, the new hire’s information needs to be added to the payroll system.

Only upon successful completion of the background check and signing a Compensation Agreement will the new hire's information be processed for payroll onboarding.

CFBO Responsibilities:

1. The CFBO is responsible for accurately inputting the new hire’s information into the payroll system. This includes, but is not limited to, salary details, tax information, benefits enrollment, and other payroll-related details.
2. The CFBO must verify that all required information has been provided and is accurate before finalizing the payroll setup.

New Joiner Periodical Check-Ins and bi-annual Review Process

New Joiner Periodical Check-Ins and Annual Review Process

To support new joiners in their first months at the company, the immediate supervisor is responsible for scheduling periodical check-ins, while the Department Lead handles a formal annual review to ensure alignment with company goals and address any concerns.

Periodical Check-Ins:

• The immediate supervisor will arrange periodical check-ins during the first few months of the new joiner’s employment.
• These check-ins involve both the new joiner and their supervisor, providing ongoing support, gathering feedback, and addressing any challenges.
• The purpose is to ensure that role expectations are clear and that the new joiner feels supported as they transition into the team.

Employee Evaluation

The Employee Evaluation Process at Give Corporation is designed to support continuous growth, open communication, and clarity in performance expectations. It serves as a structured touchpoint to assess alignment, contributions, and areas where support or development may be needed.

Self-Assessment and Evaluation Review Process

Scope:
 Applies to all Give Corporation team members.

Purpose:

• Encourage team members to reflect on their work, communication, and goals.
• Capture both employee and supervisor perspectives to inform development.
• Identify performance strengths and areas for further support or training.

Process:

• Initiation: Supervisors or Department Leads send the Self-Assessment Form to their direct reports.
  Submission: Team members complete and return the form to their immediate supervisor.
  Review: Supervisors evaluate the self-assessment, optionally conduct check-ins, and complete the Evaluation Form.
• Reporting: A completed package (Self-Assessment + Evaluation Form) is submitted to the CEO.
• Follow-Up (if applicable): The CEO may review select evaluations and reach out for further discussion.
• Documentation and Tools:

• Forms used include the Self-Assessment Review Form and the Evaluation Form.
• All documents are confidential and stored securely.

Access Control and Confidentiality

All stored documents, including contracts, identity documents, and Confirmation of Participation, must be securely stored with strict access control. Only authorized personnel will have access to this information.

The Compliance Team is responsible for ensuring that sensitive information is only accessible by authorized personnel.

Employee Complaint

The purpose of this Team Member Complaint Policy is to provide a structured and transparent process for team members to raise complaints or concerns regarding workplace issues. The policy ensures complaints are handled fairly, confidentially, and promptly while fostering a safe and respectful working environment. GiveCorporation Inc. (“Give”) seeks to ensure a safe, supportive, and respectful work environment.

This policy applies to all team members, contractors of Give and its subsidiaries. The policy applies to discrimination or harassment (such as, race, gender, age, disability), workplace bullying or unfair treatment, unsafe work conditions, violations of policies or laws and disputes with colleagues or management.

Roles and Responsibilities

Team Members

• Raise complaints in a timely and honest manner.
• Cooperate with the investigation process.

Managers and Supervisors

• Foster a respectful and supportive workplace.
• Address informal complaints and escalate formal complaints to the Compliance team.
• Ensure no retaliation occurs against complainants or witnesses.

The Compliance Team

• Receive and acknowledge complaints.
• Oversee the investigation process.
• Ensure compliance with this policy.
• Maintain confidentiality and secure records.

Steps in the Complaint Process

Step 1: Submission of Complaint

The employee submits a written complaint to the Compliance team at hr@givecorporation.com or 800 913-0163 extension 5 . The complaint should include relevant details such as:

• Description of the issue.
• Names of parties involved.
• Dates and times of incidents.
• Supporting evidence (emails, documents, witnesses).

Step 2: Acknowledgment and Initial Review

The Compliance team acknowledges receipt within three (3) business days. A preliminary assessment is conducted to determine:

• The validity and scope of the complaint.
• If immediate action is necessary (e.g., further investigation, temporary suspension, transfer).

Step 3: Investigation

An impartial investigator (internal or external) is assigned.

The investigation process will  include:

• Interviews are conducted with the complainant, the respondent, and relevant witnesses.
• Evidence is collected and reviewed.
• Findings are documented.

The investigation will aim to be completed within thirty (30) business days, though timelines may vary based on complexity

Step 4: Resolution and Outcome

Upon conclusion of the investigation, the investigator will prepare a report summarizing the findings and recommendations. Possible outcomes include:

• Substantiated Complaint: The complaint is substantiated and one of the following appropriate corrective actions  will be taken; disciplinary action, training, or policy adjustments
• Unsubstantiated Complaint: If insufficient evidence is found, the complainant will be informed of the outcome with an explanation.

Both  the complainant and respondent will receive a summary of the investigation’s outcome while ensuring confidentiality.

Step 5: Appeals Process

If either the complainant or respondent is dissatisfied with the outcome, they may file an appeal within ten (10) business days of receiving the decision. The appeal must state the reasons for contesting the outcome and provide any new evidence, if available.

A designated appeals officer or review committee will re-evaluate the case and issue a final decision within fifteen (15) business days.

Confidentiality and Protection

Give is committed to maintaining the confidentiality of all parties involved in a complaint. Information related to complaints and investigations will be shared on a need-to-know basis and stored securely. Breaches of confidentiality may result in disciplinary action.

Retaliation against team members who raise complaints or participate in investigations is strictly prohibited. Any team member found to have engaged in retaliatory behavior will be subject to disciplinary action, up to and including termination.

Training and Awareness

The organization will provide regular training to team members, managers, and supervisors on the complaint process, anti-harassment policies, and retaliation prevention. Information to educate and make employees aware of their rights and responsibilities will be provided.

Non-completion of mandatory trainings may result in reminders, warnings, or other disciplinary measures.

Monitoring and Continuous Improvement

There will be periodic reviews of complaint data to identify patterns and areas for improvement. Updates will be made to the Team member/Employee Complaint Policy based on feedback and legal changes. Compliance with legal and regulatory requirements will be monitored and may be tailored to ensure this Team member/Employee Complaint Policy remains effective and relevant.  

Offboarding

Organization-Initiated Termination

Responsible Party: Department Lead

Process:

In the event of a termination initiated by the organization, the employee or contractor will receive a termination notice in accordance with the terms outlined in their employment or contractor agreement.

The Department Lead will inform internal parties, including the CFBO, IT, Operations, Compliance and co-founders, to ensure all necessary actions are taken to manage the exit process.

Leave Notice and Stakeholder Notification

Responsible Party: Departing Employee or Departing Contractor, Department Lead

Process:
The Departing Employee or Departing Contractor must prepare and send a formal leave notice to the Department Lead at least two weeks in advance, stating the intent to leave the organization. This notice should include:

• Proposed last working day
• Details of pending tasks or projects

Upon receipt of the leave notice, the Department Lead must inform key stakeholders, CFBO, IT, Operations, Legal and co-founders, about the employee's departure and any necessary actions to prepare for the exit.

Termination Paperwork

Responsible Party: CFBO

Process:
A termination letter for the departing employee or departing contractor are handed over in line with the contractually agreed termination terms and deadlines. The termination letter does not have to be countersigned by the departing employee or contractor and is binding upon delivery via mail, email or in person with the CBFO and one other witness being present.

Upon delivery of the termination letter, the Finance team calculates the last payroll payment and terminates the departing employee or contractor in the payroll system (see section Finance further below). At the end of the year, the required reports such as 1099 or W4 will be mailed within the usual course of business for all existing and terminated participants of payroll for that year.

Internal Communication

Responsible Party: Department Lead, Departing Employee or Departing Contractor

Process:
The Department Lead will decide who will take over the tasks and communicate this decision to the Departing Employee or Departing Contractor. The Departing Employee or Departing Contractor should then, in advance, send an internal communication to notify their team and the person taking over the tasks. This communication should include:

• Details of the handover process
• Contacts for ongoing projects/tasks

Handover Documentation

Responsible Party: Departing Employee or Departing Contractor

Process:
The Departing Employee or Departing Contractor is required to create and share a comprehensive handover document with relevant parties. This document should cover all necessary knowledge, materials, and information to ensure a smooth transition, including:

• Detailed information on ongoing projects/tasks
• Key contacts and their responsibilities
• Access to relevant documents, files, and resources
• Status updates on all active assignments
• Any specific procedures, guidelines, or best practices related to their role

The goal is to ensure that the incoming team member has all the information needed to continue work seamlessly.

External Communication to Clients

Responsible Party: Department Lead

Process:
If applicable, the Department Lead should communicate the employee's exit to any clients the Departing Employee or Departing Contractor was handling, ensuring a smooth transition.

Exit Interview

Responsible Party: Department Lead

Process:
An exit interview should be conducted to gather feedback from the Departing Employee or Departing Contractor about their experience. This feedback can provide insights for improving the workplace environment.

Access Removal and Contact Information Collection

Responsible Party: IT Director, Compliance Manager

Process:
Based on the departing employee's or contractor's role, either the IT Director or the Compliance Manager is responsible for completing the Remove User Request Form and documenting all necessary details, including the individual’s updated contact information.

• IT Director: Manages forms for the Give Corporation Core Team.
• Compliance Manager: Manages forms for key custodians and the tech team.

Steps to Complete:

1. Revoke Access Rights: Remove the departing individual’s access to all company systems, software, tools, email accounts, cloud services, and other company platforms by their last working day.
2. Update Credentials: Change any shared passwords or credentials to maintain security.
3. Form Storage: Ensure all completed Remove User Request Forms are securely stored and accessible for audit or reference purposes.

Final Payments

Responsible Party: CFBO

Process:
Upon the delivery of the termination letter, the remaining days on payroll for the departing employee are calculated on a ACT/30 basis. The CFBO will instruct the AP team  to arrange for the Departing Employee or Departing Contractor’s final payments within the usual payroll cycle, including any outstanding wages, employee reimbursements and ensuring all financial obligations are settled promptly.

Update Organizational Chart

Responsible Party: IT Director

Process:
The IT Director is responsible for updating the organizational chart to reflect the employee's departure, ensuring it remains current and accurate.

Bring Your Own Device (BYOD)

Employees using personal devices for work must adhere to company security standards, ensuring devices have up-to-date antivirus software, strong passwords, and the latest security patches. GiveCorporation reserves the right to install security software on such devices. In case of loss or theft, employees must report the incident immediately, and GiveCorporation may remotely wipe company data or block access to protect sensitive information.

Employees should use unique, complex passwords that are updated regularly, enable multi-factor authentication (MFA) for accessing sensitive systems, and avoid sharing passwords with others or using the same password across multiple accounts.

For further details, refer to the Information Security Program, which outlines the Bring Your Own Device policy in full.

Device Security Confirmation for New Joiners

Responsible Party: IT Director

Process:

1. Upon onboarding a new joiner, the IT Director must collect information about the operating system being used on the new joiner’s laptop.
2. For Windows users: request a screenshot confirming that antivirus software is enabled. The evidence should be stored.
3. Obtain confirmation from all new joiners, regardless of the operating system, that the firewall is enabled on their laptops.

Conflict Resolution

To maintain a respectful and harmonious work environment, the following process should be adhered to when addressing HR-related issues:

1. Initial Reporting:

• Any concerns or conflicts should be reported directly to the employee's Department Lead in writing. This ensures that the issue is documented and can be addressed promptly and appropriately.
• If the concern involves the Department Lead, the employee should escalate the matter directly to the company's co-founders.

2. Investigation Process:

• Upon receiving a complaint, the Department Lead (or co-founders, in applicable cases) will initiate an investigation, ensuring that the matter is handled discreetly, anonymously, and ethically.
• All parties involved in the conflict resolution process are expected to adhere strictly to the organization's Code of Conduct throughout the investigation and resolution process.
• The organization commits to maintaining impartiality throughout the investigation, with all parties treated equally and respectfully.

3. Decision-Making:

• Based on the findings, an independent decision will be made to address the conflict effectively. The aim is to resolve the issue fairly, ensuring that all parties understand the outcome.

4. Confidentiality and Anonymity:

• All conflict resolution matters will be treated with strict confidentiality to protect the privacy and integrity of the individuals involved.
• The organization ensures that any actions or decisions taken will be done so with the utmost respect for the individuals concerned, without any bias or discrimination.

Policies and Procedures

All organizational policies and procedures will be posted on Google Drive, accessible to all Give members.

The Compliance Team is responsible for keeping them updated and replacing them with the latest versions when any changes occur. In the event of updates, the Compliance Team will notify all Give Corp members via the compliance-general Slack channel.

Give Corporation Core Teams Overview

CEO & Corporate Strategy

• Joshua Rowley: Chief Executive Officer (CEO), Co-Founder

Compliance, Risk & Technology

• Aaron Miller: Chief Risk and Technology Officer (CRTO), Co-Founder
• Loraine Stewart: Chief Compliance Officer (CCO)
• Kateryna Ihnatovych: Compliance Manager
• Gjorge Uzunov: Risk Manager

Customer Support

• Chris Miller: IT Director
• Jalijah Daniel: Client Service Manager

Finance

• Michael Brinker: Chief Finance and Business Officer (CFBO)

Growth

• Adam Aberra: Chief Revenue Officer
• Nikhil Patel: Senior Account Executive
• Brendan Landis: Sales Development Representative

Underwriting

• Heather Wusterbarth: Underwriting Associate
• Aniello D'Antonio: Underwriting Associate

The information contained herein is intended to provide a general overview of the Company’s policies and procedures relating to compliance with this Policy and does not constitute legal advice or a complete description of the laws and regulations relating to this Policy. The Company has made every effort to ensure the accuracy and completeness of this Policy.  This document is intended to provide guidance to employees of Company on how to comply with applicable laws and regulations related to this Policy. Employees should consult with the Legal or Compliance Department if they have any questions about the Policy or how to comply with it. Company reserves the right to modify or update this Policy at any time without notice. Employees are responsible for reviewing the Policy on a regular basis to ensure that they are aware of any changes. This Policy applies to all employees of Company, regardless of their position or location unless stated otherwise in the Policy. Employees are responsible for complying with the Policy and for reporting any suspected violations to their respective supervisor, the Legal Department, AMLCO or respective recipient of such violation as outlined in this Policy.