> FICTITIOUS DOCUMENT — FORGE DEMO ONLY · SPECIMEN

# Policy Memo — Code of Ethics: Quarterly Attestation & Personal-Trading Reporting

**Alderbrook Wealth Partners**
**To:** All supervised persons
**From:** Ellen Doran, Chief Compliance Officer
**Date:** January 12, 2026
**Re:** 2026 quarterly Code-of-Ethics attestation duty and personal-trading reporting

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This memo restates, for the 2026 calendar year, each supervised person's ongoing obligations under
the Firm's Code of Ethics. Nothing here changes the Code; it is a reminder of the two recurring
duties every member of the Firm owes: the **quarterly attestation** and the **personal-trading
reporting rule**.

## 1. Quarterly attestation duty

Every supervised person must complete and submit a Code-of-Ethics attestation **once each calendar
quarter**. In the attestation you confirm that, for the quarter, you have complied with the Code, met
your personal-trading reporting obligations, upheld your fiduciary duty to clients, and reported any
conflict or violation you are aware of.

The attestation is submitted to the Chief Compliance Officer and retained in the compliance file.

### Due dates (2026)

| Quarter | Period covered | Attestation due |
|---|---|---|
| Q1 | Jan 1 – Mar 31 | **April 30** |
| Q2 | Apr 1 – Jun 30 | **July 30** |
| Q3 | Jul 1 – Sep 30 | **October 30** |
| Q4 | Oct 1 – Dec 31 | **January 30** (following year) |

Submit on or before the due date. If you cannot submit on time, tell the CCO **before** the due date;
a late or missing attestation is itself a compliance exception and will be tracked as one.

## 2. Personal-trading reporting rule

The Code's personal-trading rule protects clients by making sure no one at the Firm trades in a way
that disadvantages a client. Each supervised person must:

- **Report reportable personal securities transactions and holdings** as required by the Code, on the
  schedule the Code sets. Your quarterly attestation is where you confirm this reporting is complete
  and current.
- **Pre-clear** any transaction the Code designates as requiring pre-clearance, in advance, with the
  CCO.
- **Never** use knowledge of client activity, or of the Firm's intended activity, for personal
  advantage, and never place a personal trade ahead of a client's interest.

Because the Firm builds client portfolios from a small menu of pooled funds and accepts no
third-party compensation, most personal activity is low-conflict — but the reporting duty applies
regardless, and the attestation is not optional.

## 3. Questions

Direct any question about what is reportable, what requires pre-clearance, or how to file to the
Chief Compliance Officer. When in doubt, report or ask before you act.

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*SPECIMEN — Alderbrook Wealth Partners compliance file.*