Summary of Whistleblower Policy

    Peak Trust Company (the “Company”) and its subsidiaries has adopted Written Procedures for the Confidential Receipt, Consideration and Retention of Reports of Evidence of Material Violations.

    Under the Procedures, officers, directors, employees and others associated with the Company ("Reporting Persons") are to be provided an effective and confidential protocol for reporting suspected Material Violations (as defined in the Procedures). The Reporting Form is intended to provide at least one means for such reporting of Material Violations.

    Under the Procedures, upon becoming aware of any suspected Material Violation, a Reporting Person is required to promptly contact the Chairman of the Audit Committee (the "Chairman") and inform the Chairman of the details of the suspected Material Violation (a "Reported Violation"). Although Reporting Persons may select any means (e.g., written, oral, email, etc.) to communicate suspected Material Violations, the Reporting Form will provide an anonymous means of communicating with the Chairman and the Audit Committee and will assure confidentiality.

    Upon completion of the Reporting Form and your description of the Material Violation, the Chairman and the Company’s Chief Compliance Officer (“CCO”) will be sent an anonymous email with the text of your report.

    • No records of the sender will be kept.
    • There is no technical means of determining who the Reporting Person is.
    • No attempt will be made to make any such determination.
    • In the event the Reporting Person discloses him- or herself, they will not be disciplined because he or she made a Reported Violation in good faith.
    • The Chairman and CCO shall use all reasonably possible means to protect the confidentiality of the Reporting Person making the report.