Any involvement or help in managing a customer’s private funds must be limited to the services set down in the customer’s ISP, unless more extensive assistance is approved by a member of the Company’s leadership team.

Any employee who helps a customer manage their funds must maintain detailed records of all transactions and exchanges of funds, and submit this documentation to the
employee’s lead monthly. At a minimum, each financial record will include:

• The date of transaction.
• The amount of the transaction.
• A valid receipts for all expenditures made on behalf of the customer.
• A detailed written explanation outlining the purpose for the transaction.

Any employee who helps a customer manage their personal funds must not:

• Inappropriately expend a customer’s personal funds.
• Use a customer’s funds for personal use or for the employee’s own benefit
• Co-mingle a customer’s personal funds with Company funds or the personal funds of the employee or another individual’s funds.
• Seek or obtain guardianship or conservatorship over a customer’s personal funds or financial accounts.
• Witness any will or insurance policy in which employee or the Company is beneficiary.

Any employee who is found to have engaged in the theft or misuse of a customer’s funds, or has otherwise violated these policies will be subject to disciplinary action, up to and including immediate termination.

A customer’s personal property should be treated with the same respect and deference as monetary funds.