Anthony Ghoston PresidentCOOCCO Dividend Assets Capital Ridgeland S

• Anthony Ghoston, President/COO/CCO, Dividend Assets Capital, Ridgeland, S. C. • Kyle Medlin, Second VP, FINRA/SEC Regulatory Compliance Department, Mutual of America Life Insurance Company, New York • Michael Shaub, Professional Program Director, Dept. of Accounting, Texas A&M University’s Mays Business School, College Station, Texas • Ronald Duska, Ph. D, Recognized Expert in Ethics in Financial Planning, Philadelphia

IA Watch Ethics Webinar October 18, 2016 • The Evolution of Business Ethics • Present a Consistent Message • Lessons from the Wells Fargo Case • Insider Trading • FCPA

IA Watch Ethics Webinar October 18, 2016 Evolution of Business Ethics • • • Ethics always around. Ethos means customs or habits. In business you need trust. In finance, with Huebner. Look out for client’s interest before yours. • Fiduciary in its simplest form.

IA Watch Ethics Webinar October 18, 2016 • • • Weakness Ignorance Slippery Slope Arrogance Rationalization Docility Why Good People Do Bad Things

IA Watch Ethics Webinar October 18, 2016 Sensitivity Exercise • Going along with a middle-aged client with minimal investment experience who insists on investing a significant portion of his total assets in high-risk funds. • Any Problem? ? • None • Minor • Moderate • Major

IA Watch Ethics Webinar October 18, 2016 • Turning over your lower income clients, to a junior colleague because you don’t have time to adequately service their accounts. You originally promised those clients you would be their lifelong agent • Any Problem? • None • Minor • Moderate • Major

IA Watch Ethics Webinar October 18, 2016 • Not revealing information to your manager about possible market conduct violations of one of the producers affiliated with your office. • Any Problem? • None • Minor • Moderate • Major

IA Watch Ethics Webinar October 18, 2016 • • • Screening New Hires Training Existing Employees Monitoring Employees Disciplining Violators

DIVIDEND ASSETS CAPITAL, LLC IA Watch Ethics and Integrity Presentation Anthony J. Ghoston Chief Operating Officer & CCO October 18, 2016

DIVIDEND ASSETS CAPITAL, LLC Topics • • Tone at the top Clients dig deep in DDQs and COE Ethics tips, monitoring, and other practices Policies and procedures 10

DIVIDEND ASSETS CAPITAL, LLC Ethics: Tone at the Top 1. Who is responsible? 2. What should the tone feel like? 3. What are some components of a good ethics program? 11

DIVIDEND ASSETS CAPITAL, LLC Ethics: Clients Dig Deep into DDQ and COE A deeper look at 1. 2. 3. Annual Questionnaires COE Employee Handbook and policies concerning employee oversight More interviews with employees to better understand the Ethical Culture 12

DIVIDEND ASSETS CAPITAL, LLC Ethics Tips • TIPs: 1. 2. 3. Clear and concise communications Awareness and training Testing the effectiveness of the firm’s ethics • Monitoring: Ethics Committee, Compliance or Risk Management 1. 2. 3. 4. 5. 6. Ethics Committee, compliance , risk management Email and social media Sales and clients Conversations with your clients Risk management Human resources. 13

DIVIDEND ASSETS CAPITAL, LLC Polices and Procedures • Enforce compliance with ethical policies and procedure • Legal counsel’s involvement with your policies and procedures • Continuous review of incentive-based pay policies and alignment 14

DIVIDEND ASSETS CAPITAL, LLC Conclusion: Ethical Leadership • Make it clear: Ethics is the way we operate • Openly discuss ethical challenges and the complexity with staff • Cultivate a respectable environment where people can speak up about ethics • Identify why consumers buy from you, and do the right thing no matter what. • Make sure that no one is exempted from meeting the ethical standards of the firm. 15

IA Watch Ethics Webinar October 18, 2016 • An ethical scenario You’re The CCO. You Have Very 3 Strong-willed Corporate Officers Who Are Access Persons Under The Code. One Of Them Will Only Allow An Outside Consultant To Review His Brokerage Statements Each Quarter. Once The Quarterly Review Is Complete, The Officer Takes His Statements Back Home. 1. Is This Acceptable? 2. If Not, What Is Wrong? 3. And What Should You Do?

IA Watch Ethics Webinar October 18, 2016 • Q&A • Final Takeaways

• Anthony Ghoston, President/COO/CCO, Dividend Assets Capital, Ridgeland, S. C. • Kyle Medlin, Second VP, FINRA/SEC Regulatory Compliance Department, Mutual of America Life Insurance Company, New York • Michael Shaub, Professional Program Director, Dept. of Accounting, Texas A&M University’s Mays Business School, College Station, Texas • Ronald Duska, Ph. D, Recognized Expert in Ethics in Financial Planning, Philadelphia