Code of Ethics

1. Vision and Purpose

   As professional employees of THE PREMIER LIFE AND GENERAL ASSURANCE CORPORATION (Formerly: THE PREMIER INSURANCE AND SURETY CORPORATION - TPISC), we are committed to doing what is right and honorable.

   We set high standards for ourselves and we aspire to meet these standards in all aspects of our lives—at work, at home, and in service to our profession.

   This Code of Ethics and Professional Conduct describes the expectations that we have of ourselves and our fellow employees in the non-life insurance community. It articulates the ideals to which we aspire as well as the behaviors that are mandatory in our professional.

   The purpose of this Code is to instill confidence in our profession and to help an individual become a better employee. We do this by establishing a profession-wide understanding of appropriate behavior. We believe that the credibility and reputation of the company–TPISC- is shaped by the collective conduct of individual employees.

   We believe that we can advance our profession, both individually and collectively, by embracing this Code of Ethics and Professional Conduct.

   We also believe that this Code will assist us in making wise decisions, particularly when faced with difficult situations where we may be asked to compromise our integrity or our values.

   Our hope that this Code of Ethics and Professional Conduct will serve as a catalyst for others to study, deliberate, and write about ethics and values.

   Further, we hope that this Code will ultimately be used to build upon and evolve our profession.

2. Persons to Whom the Code Applies

   The Code of Ethics and Professional Conduct applies to:

   1. All TPISC employees (officers and staff)
   2. Individuals who are not employees of TPISC

3. Structure of the Code

   The Code of Ethics and Professional Conduct contains standards of conduct which are aligned with the five values that were identified as most important to the non-life insurance community.

4. Values that Support this Code

   The values that formed the basis of decision making and guide to their actions defined as most important were:

   • Responsibility
   • Respect
   • Fairness
   • Honesty

   This Code affirms these five values as its foundation.

5. Aspirational and Mandatory Conduct

   The Code of Ethics and Professional Conduct includes both aspirational standards and mandatory standards.

   The aspirational standards describe the conduct that we strive to uphold as employees. Although adherence to the aspirational standards is not easily measured, conducting ourselves in accordance with these is an expectation that we have of ourselves as professionals—it is not optional.

   The mandatory standards establish firm requirements, and in some cases, limit or prohibits employee behavior. Employees who do not conduct themselves in accordance with these standards will be subject to disciplinary procedures before Ethics Review Committee [Please refer to Manual of Good Governance].

1. Description of Responsibility

   Responsibility is our duty to take ownership for the decisions we make or fail to make, the actions we take or fail to take, and the consequences that result.

2. Responsibility: Aspirational Standards

   As employees at TPISC:

   1. We make decisions and take actions based on the best interests of the company, society, public safety, and the environment.
   2. We accept only those assignments that are consistent with our background, experience, skills, and qualifications.
   3. We fulfill the commitments that we undertake – we do what we say we will do [palabra de honor].
   4. When we make errors or omissions, we take ownership and make corrections promptly. When we discover errors or omissions caused by others, we communicate them to the appropriate body as soon they are discovered. We accept accountability for any issues resulting from our errors or omissions and any resulting consequences.
   5. We protect proprietary or confidential information that has been entrusted to us.
   6. We uphold this Code and hold each other accountable to it.

3. Responsibility: Mandatory Standards

   As employees at TPISC, we require the following of ourselves and our fellow employee:

   Regulations and Legal Requirements

   1. We inform ourselves and uphold the policies, rules, regulations and laws that govern our work, professional, and volunteer activities.
   2. We report unethical or illegal conduct to appropriate management committee/body and, if necessary, to those affected by the conduct.

   Ethics Complaints

   1. We bring violations of this Code to the attention of the appropriate management committees/body for resolution.
   2. We only file ethics complaints when they are substantiated by facts.
   3. We pursue disciplinary action against an individual who retaliates physically against a person raising ethics concerns.

1. Description of Respect

   Respect is our duty to show a high regard for ourselves, others, and the resources entrusted to us. Resources entrusted to us may include people, money, reputation, the safety of others, and natural or environmental resources [amor propio].

   An environment of respect engenders trust, confidence, and performance excellence by fostering mutual cooperation — an environment where diverse perspectives and views are encouraged and valued.

2. Respect: Aspirational Standards

   As employees at TPISC:

   1. We inform ourselves about the norms and customs of others and avoid engaging in behaviors they might consider disrespectful.
   2. We listen to others’ points of view, seeking to understand them.
   3. We approach directly those persons with whom we have a conflict or disagreement.
   4. We conduct ourselves in a professional manner, even when it is not reciprocated.

3. Respect: Mandatory Standards

   As employee of TPISC, we require the following of ourselves and our fellow employee:

   1. We negotiate in good faith.
   2. We do not exercise the power of our expertise or position to influence the decisions or actions of others in order to benefit personally at their expense.
   3. We do not act in an abusive manner toward others.
   4. We respect the property rights of others.

1. Description of Fairness

   Fairness is our duty to make decisions and act impartially and objectively. Our conduct must be free from competing self-interest, prejudice, and favoritism.

2. Fairness: Aspirational Standards

   As employees at TPISC:

   1. We demonstrate transparency in our decision-making process.
   2. We constantly re-examine our impartiality and objectivity, taking corrective action as appropriate.
   3. We provide equal access to information to those who are authorized to have that information.
   4. We make opportunities equally available to qualified candidates.

3. Fairness: Mandatory Standards

   As employees at TPISC, we require the following of ourselves and our fellow employees:

   Conflict of Interest Situations

   1. We proactively and fully disclose any real or potential conflicts of interest to the appropriate management committee/body stakeholders.
   2. When we realize that we have a real or potential conflict of interest, we refrain from engaging in the decision-making process or otherwise attempting to influence outcomes, unless or until:
      • we have made full disclosure to the affected stakeholders;
      • we have an approved mitigation plan;
      • we have obtained the consent of the stakeholders to proceed.

   Favoritism and Discrimination

   3. We do not hire or fire, reward or punish, or award or deny contracts based on personal considerations, including but not limited to, favoritism, nepotism, or bribery.
   4. We do not discriminate against others based on, but not limited to, gender, race, age, religion, disability, nationality, or sexual orientation.
   5. We apply the rules of the organization (employer, non-life insurance governing bodies, or other group) without favoritism or prejudice.

1. Description of Honesty

   Honesty is our duty to understand the truth and act in a truthful manner both in our communications and in our conduct.

2. Honesty: Aspirational Standards

   As employees at TPISC:

   1. We earnestly seek to understand the truth.
   2. We are truthful in our communications and in our conduct.
   3. We provide accurate information in a timely manner.
   4. We make commitments and promises, implied or explicit, in good faith.
   5. We strive to create an environment in which others feel safe to tell the truth.

3. Honesty: Mandatory Standards

   As employees at TPISC, we require the following of ourselves and our fellow employees:

   1. We do not engage in or condone behavior that is designed to deceive others, including but not limited to, making misleading or false statements, stating half-truths, providing information out of context or withholding information that, if known, would render our statements as misleading or incomplete.
   2. We do not engage in dishonest behavior with the intention of personal gain or at the expense of another.

A Conclusion: Code of Ethics and Professional Conduct

The result of this effort - Code of Ethics and Professional Conduct - not only describes the ethical values to which management of and staff of THE PREMIER LIFE AND GENERAL ASSURANCE CORPORATION aspires, but also addresses the specific conduct that is mandatory for every individual bound by this Code.

Violations of the Code of Ethics and Professional Conduct may result in sanctions by TPISC under the ethics Case Procedures. That as employees of TPISC, our company takes its commitment to ethics very seriously and we hold ourselves and our peers at THE PREMIER LIFE AND GENERAL ASSURANCE CORPORATION in the non-life insurance community accountable to conduct ourselves in accordance with the provisions of this Code.

B Glossary

Abusive Manner. Conduct that results in physical harm or creates intense feelings of fear, humiliation, manipulation, or exploitation in another person.

Conflict of Interest. A situation that arises when a employees of THE PREMIER LIFE AND GENERAL ASSURANCE CORPORATION is faced with making a decision or doing some act that will benefit the employees or another person or organization to which the employees owes a duty of loyalty and at the same time will harm another person or organization to which the employees owes a similar duty of loyalty. The only way employees can resolve conflicting duties is to disclose the conflict to those affected and allow them to make the decision about how the employees should proceed.

Duty of Loyalty. A person’s responsibility, legal or moral, to promote the best interest of an organization or other person with whom they are affiliated.

THE PREMIER LIFE AND GENERAL ASSURANCE CORPORATION. The totality of THE PREMIER LIFE AND GENERAL ASSURANCE CORPORATION including its committees, groups, and chartered components such as chapters, colleges, and specific interest groups.

Employee. A person who has joined the, THE PREMIER LIFE AND GENERAL ASSURANCE CORPORATION and engaged in an activity that contributes to the business portfolio, or program, as part of the profession.