Third-Party Code of Conduct

At Pan-American Life Insurance Group (PALIG), we are people you can trust for life. This trust is built on our long-standing tradition of operating with honesty and integrity since our founding in 1911.

To uphold and strengthen this trust, we seek to collaborate with Third Parties who share our values and adhere to high ethical standards. This Code of Conduct provides guidance to our Third Parties on our operational principles and our expectations of them.

Our reputation with policyholders, regulators, the public, and Third Parties is crucial to our success. It influences our business, and therefore, it is essential that each of us protects this reputation by adhering to this Code.

The trust our customers have in us is one of our most valuable assets. We maintain that confidence with your adherence and support.

Sincerely,

José S. Suquet

Chairman of the Board & CEO

Introduction

Pan-American Life Insurance Group (PALIG) believes a strong relationship with our Third Parties is the key to ensuring our company's success. The Third Party Code of Conduct was created to communicate our expectations in five value areas: Authenticity, Transparency, Accountability, Collaboration, and Integrity.

To ensure consistency and mutual commitment, we require that our Third Parties, including their employees, representatives, and subcontractors, comply with this Third Party Code of Conduct. This Code does not replace specific contractual requirements, but rather is intended to supplement our third-party contracts. If a contractual term is stricter than this Code, the Third Party must meet the stricter contractual requirement. Further, actions by a Third Party must be highly ethical regardless of whether the Code and/or the applicable contract specifically address a situation.

  • We are genuine and communicate openly, remaining true to one’s ideas, opinions, words and actions.

  • We are straightforward and open about everything we say, do and convey.

  • We take responsibility for our actions and honor commitments.

  • We believe in the power of working together to achieve common goals. Our contributions are thoughtful, intentional, proactive and empathic.

  • We are honest, ethical and build trust through principles judgment and responsible actions.

Scope

This Code applies to any entity or individual who provides services to PALIG and/or its subsidiaries/affiliates, including but not limited to producers, vendors, suppliers, agents, reinsurers, third party administrators, business partners, network providers, contractors, and subcontractors.

The Code does not cover every issue that may arise but sets out basic principles that must be adhered to in providing services or performing any activities on behalf of PALIG and its subsidiaries/affiliates.

Third Parties are expected to use their own best discretion to ensure compliance with topics outside of this Code.