GuideOne Mutual Insurance Group1 Vendor Code of Business Conduct Overview: By conducting our business operations according to the highest standards of honesty, integrity, and respect for individuals, we demonstrate every day that our business partners' trust in GuideOne is well placed. GuideOne expects its vendors to follow our commitment to integrity by complying with all applicable laws and regulations, and by acting with integrity and ethically at all times. This Vendor Code of Business Conduct applies to all persons, businesses, and other entities that are engaged to provide goods or services to GuideOne. As a vendor of GuideOne, you must ensure that your personnel (this includes your employees, agents, subcontractors, and others acting on your behalf) adhere to this Vendor Code of Business Conduct and their contractual obligations while conducting business with or on behalf of GuideOne. Vendors are expected to train their personnel on this Vendor Code of Business Conduct. A vendor must immediately inform GuideOne when any situation develops that causes, or is likely to cause, the vendor or its Personnel to operate in violation of the Vendor Code of Business Conduct. A vendor’s noncompliance with the terms of this Vendor Code of Business Conduct may, at GuideOne's discretion, result in the termination of the contract entered into between GuideOne and the vendor. The obligations in this Vendor Code of Business Conduct are general principles with which a vendor must comply. More restrictive requirements may be set forth in the contract entered into between GuideOne and the vendor. If there is any conflict between the terms of this Vendor Code of Business Conduct and any such contract, the terms of such contract shall control. Legal and Regulatory Compliance Practices: GuideOne is committed to obeying the law wherever it conducts business. As our vendor, you must comply will all federal, state, and local laws and regulations applicable to your business and the services provided to GuideOne. Employment and the Workplace: GuideOne maintains a secure work environment in which people are treated fairly, with dignity and respect. We expect our workplaces to be free from discrimination, harassment, drugs, and violence. As our vendor, we expect you to support these workplace goals in the following ways: Fair Employment Practices: You must not engage in any unlawful employment practices and must respect the rights granted to your personnel under applicable labor, wage and employment laws applicable to your business and employees. No Discrimination: You must not engage in unlawful discrimination against your personnel, or against employees, agents or contractors of GuideOne. We expect you to make all employment decisions based on legitimate, non-discriminatory business reasons and without regard to protected characteristics such as race, color, gender, religion, age, national origin, disability, veteran status, sexual orientation, gender identity, marital status, ancestry, or citizenship status. No Harassment: You must not engage in behavior that is harassing, intimidating, or otherwise creates a hostile or offensive work environment. This applies not only with respect to your personnel who perform services on behalf of GuideOne, but also to GuideOne’s employees and any other individuals your personnel may encounter or interact with in the course of providing services. Examples of harassing and intimidating behavior include: unwanted physical contact; displaying offensive material or telling offensive jokes; threats of termination or lost opportunity based on race, color, gender, religion, age, national origin, disability, veteran status, sexual orientation, gender identity, marital status, ancestry, or citizenship status; conduct of a sexual, racial, or other nature that interferes with someone’s work performance or creates an intimidating, hostile, or offensive work environment; and threatened or actual violence. No Drugs, Alcohol, or Violence: GuideOne prohibits the sale, distribution, purchase, possession, or use of illegal drugs, as well as the abuse of legally prescribed drugs, on GuideOne's premises or anywhere else while working on company business. The possession, consumption, or use of alcoholic beverages at GuideOne-sponsored company functions may occur only with prior approval from the GuideOne executive in charge of the event. When alcohol is served at GuideOne-sponsored events, you should always use good judgment and exercise moderation. Furthermore, GuideOne does not tolerate violent or threatening behavior. While performing services for GuideOne, your personnel may not engage in or threaten violent conduct or bring dangerous weapons or substances to any GuideOne workplace location or off-site company function. Security: While performing services on site at any of GuideOne’s offices, you and your personnel must comply with GuideOne’s badging, parking, and security policies. Background Investigations: It is important to GuideOne to comply with Federal laws prohibiting financial services companies like GuideOne2 from employing or doing business with individuals who have been convicted of certain crimes. Accordingly, we expect our vendors to appropriately screen personnel assigned to perform services for GuideOne. Privacy and Information Protection: You and your personnel must keep confidential, proprietary, and sensitive information private and secure at all times. Your specific duties and obligations with respect to privacy and information protection will be set forth in your contracts with GuideOne, but it is expected that at a minimum you will use the same degree of care exercised to protect your own private, confidential or proprietary information. Use of GuideOne’s Assets: Vendors may use GuideOne's property and physical assets only to provide services to or fulfill their contractual obligations with GuideOne, with permission from GuideOne. This property includes, but is not limited to, computers, e- mail, internet/intranet, fax, phone, and copiers. Your personnel are prohibited from using these assets to send, receive, or view inappropriate material, including offensive, threatening, discriminatory, or sexually explicit material. Your personnel may not download any software, whether business or personal, to GuideOne’s computers without prior written authorization from GuideOne. User IDs and passwords issued to your personnel are for the exclusive use of the intended recipients and for the specific business use for which they are issued. User IDs and passwords may not be shared with others, including other individuals within the vendor's organization. Accuracy of Records: You must keep complete and accurate records of all matters related to your business with GuideOne, including financial records. You must never tamper with, manipulate, alter, or conceal any business record and must never make a false or misleading entry on any record or report. Your practices must conform to the industry rules and standards for maintaining and retaining records. Integrity in the Marketplace/Business Practices: GuideOne’s reputation for integrity is critical to our ability to develop and sustain trust with our customers, employees, and business partners. Our reputation for integrity depends, in part, on the integrity of our vendors. You must compete fairly, act with integrity in financial transactions, carefully and accurately report financial information, and refrain from any improper or unlawful business practices. The following provisions, which apply to our employees, also apply to our vendors and their personnel: Conflicts of Interest: GuideOne’s employees must act in the best interest of GuideOne, and must have no relationships, financial or otherwise, with any vendor that might conflict or appear to conflict with their duty to act in GuideOne’s best interests. We expect that you, as our vendor, will refrain from any activity or conduct that could create real or perceived conflicts of interest. For example, if a vendor's employee has a family or other personal relationship with an employee of GuideOne, or if a vendor has any other relationship with an employee of GuideOne that might create an actual or potential conflict of interest, the vendor must disclose this information to GuideOne. If you have any reason to suspect a potential conflict, you should timely notify your primary business contact at GuideOne of any relevant facts so that you and GuideOne can assess the situation and mitigate or resolve the conflict. Gifts and Entertainment: Whether given or received, gifts and entertainment must never improperly influence business decisions. Gifts and entertainment are broadly defined to include, but are not limited to, trips, entertainment, benefits, events and any other gratuitous item or thing of value. The general rules for gifts and entertainment are described in the paragraphs that follow. Please note, however, that some business groups within GuideOne may impose greater restrictions on gifts and entertainment than outlined below. It is the responsibility of the vendor to understand and comply with any gifts and entertainment restrictions that may apply to the person(s) or group(s) with whom you do business at GuideOne. Generally, employees of GuideOne may give or receive gifts only if they are inexpensive gifts of a promotional nature, or if they are customary, reasonable, and proper under the particular business circumstances. Gifts are subject to a presumptive limit of no more than US$100 per person. Under no circumstances may a vendor offer to or accept from any employee of GuideOne gifts of cash or cash equivalents (such as gift certificates) that can be converted to cash, loans, or stock options. Likewise, GuideOne vendors may not provide goods or services to any GuideOne employee or director at less than market value, and any discounts provided for goods or services must be at the same rates offered to the general public. Entertainment, whether provided or accepted by a vendor, should always have a legitimate business purpose. GuideOne expects you to use good judgment in offering or accepting entertainment; the entertainment should not be lavish, unusual, or extravagant. OFAC: As a vendor, you must never knowingly facilitate or participate in any terrorist financing, or other financial criminal activity, and GuideOne expects you to promptly report any suspicious activity. You must also respect the U.S. government’s policies on trade sanctions, and comply with the U.S. trade sanction program. Anti-Bribery/Anti-Corruption: You must not participate in bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private sector, including employees and directors of GuideOne. You must comply with all applicable anti-corruption laws, including the U.S. ForeignCorrupt Practices Act, as well as laws governing lobbying, gifts and payments to public officials, political campaign contribution laws, and other related regulations. Reporting Potential Misconduct & Retaliation-Free Workplace: Any individual with knowledge of an actual or potential violation of the terms and conditions of this Vendor Code of Business Conduct or any applicable laws and regulations in connection with work performed for GuideOne must report this knowledge to their primary business contact, or, alternatively, contact GuideOne's EthicsPoint Reporting Portal at: 1-844-692-6081, or www.guideone.ethicspoint.com GuideOne strictly enforces its non-retaliation policy, which protects those who, in good faith, report suspected wrongdoing. Likewise we expect that you will not engage in retaliation against your personnel, who, in good faith, report potential violations of the law, potential violations of this Vendor Code of Business Conduct, or any other alleged wrongdoing. 1 GuideOne Insurance Group (“GuideOne”) includes the following companies: GuideOne Insurance Company; GuideOne Specialty Insurance Company; GuideOne America Insurance Company; GuideOne Elite Insurance Company; GuideOne National Insurance Company; Lutheran Trust, Inc.; Lutheran Asset Management, Inc.; Church Asset Management, Inc.; and Career General Agency, LLC. 2 For example, 18 U.S.C. 1033 applying to individuals who have been convicted of crimes of dishonesty or breach of trust.