Focus Financial Partners : Policy for Complaint Procedures for Accounting and Compliance Matters

FOCUS FINANCIAL PARTNERS INC.

POLICY FOR COMPLAINT PROCEDURES FOR ACCOUNTING

AND COMPLIANCE MATTERS

What Is a Quick Summary of This	1.	You can make a good faith complaint about any questionable accounting or compliance
Policy?	matter. You can do so anonymously if you wish.
	2.	You will not be retaliated against for making a complaint in good faith.
	3.	The Audit and Risk Committee will oversee the review of your complaint.
What Is the Purpose of This Policy?	To facilitate the reporting of complaints about questionable accounting and compliance matters.

Who Is Covered by This Policy?

Any director, officer or employee of Focus and any director, principal, officer or employee of any Focus partner firm or subsidiary.

What Accounting Matters Should I Report Under This Policy?

Any matters involving accounting, internal controls or auditing, including:

• Fraud in the preparation or audit of any Focus financial statements or records;
• Deficiencies in Focus's internal accounting controls;
• Misrepresentations about Focus's financial records, financial statements or audit reports by or to a senior officer or accountant; and
• Any failure to fully and fairly report Focus's financial condition.

What Compliance Matters Should I	Potential violations of applicable laws, rules or regulations or any of Focus's codes, policies or
Report Under This Policy?	procedures.

How Do I Make a Complaint About a Questionable Accounting or Compliance Matter?

You can make your complaint in person, by phone or in writing to the Chief Compliance Officer or a principal of your firm, or to Focus's General Counsel. Complaints made to Chief Compliance Officers and principals of Focus partner firms will be forwarded to Focus's General Counsel.

Alternatively, you can make your complaint through Focus' anonymous whistleblower hotline, which can be reached by phone at 844-399-5153 or online at http://www.openboard.info/FOCS/. You should only make complaints under this Policy in good faith.

What Happens After I Make a	Focus's General Counsel will acknowledge receipt of the complaint if possible. This will not be
Complaint?	possible if your complaint is anonymous.
	Focus's General Counsel or another person deemed appropriate by the Audit and Risk Committee
	will review the complaint under the oversight of the Audit and Risk Committee.
	Confidentiality of the complaint will be maintained to the fullest extent possible.

What if I am Retaliated Against for Making a Complaint Under This Policy?

If you believe you have been harassed, threatened, demoted, dismissed, discriminated against or otherwise retaliated against for making a complaint under this Policy, you may file a complaint with Focus's General Counsel. Focus will promptly take appropriate corrective action.

How will the Audit and Risk Committee be Kept Informed About Complaints Made Under This Policy?

Focus's General Counsel will log the receipt, investigation and resolution of all complaints about questionable accounting or compliance matters. Periodically, Focus's General Counsel will provide a summary report to the Audit and Risk Committee.

Adopted: July 25, 2018

Amended: November 12, 2020

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