Code of Professional Conduct for Agents

The Company is committed to treating our clients fairly and ethically.  That is why we have adopted this Code of Professional Conduct (Code) for our agents.  The Company agents have a responsibility to treat clients and other agents fairly and ethically.  Failure to adhere to these principles may result in disciplinary actions, up to and including termination for cause.

 Principles

The Company commits itself, and requires its agents to:

  1. Conduct business according to high standards of honesty and fairness and treat our clients and agents as we would expect to be treated.
  2. Provide competent and client-focused sales and service.
  3. Compete fairly.
  4. Provide advertising and sales material that is clear, honest and fair.
  5. Handle client complaints and disputes fairly and promptly.
  6. Maintain a system of supervision and monitoring reasonably designed to demonstrate The Company’s commitment to and compliance with these principles.  In addition, The Company has adopted the following policies specific to The Company’s individually sold life insurance, annuity and long term care insurance (hereby referred to as “insurance products”).  It is the policy of The Company, in the sale of its insurance products, to meet the needs of its clients.

The Company commits itself and requires agents to:

  1. Enter into life insurance transactions that assist clients in meeting their insurable needs and objectives.
  2. Provide recommendations to purchase individually sold annuities, life insurance or long term care that are suitable based upon relevant information obtained from clients.
  3. Maintain a process to comply with laws and regulations that are related to this Code in the marketing and sale of insurance products or related to the running of an insurance business.
  4. Proactively seek to improve the life insurance industry’s practices for marketing and sales of insurance products.
  5. Adopt and support the concepts in this Code. To disclose any violations of this Code so that The Company may take corrective action upon where deemed applicable.

 Use Qualified and Trained Agents

  1. Agents will be of good character and business repute and have the appropriate qualifications implemented by The Company.
  2. Agents will be licensed, appointed (where necessary), and meet other applicable state requirements required to solicit insurance products.
  3. Agents will be properly trained on how to comply with laws and regulations, The Company procedures, and with this code, as appropriate.
  4. Agents will be familiar with information that The Company makes available about The Company’s approved product(s) and the features and operations of the product(s). The information may be provided or made available through various methods, including sales, marketing, or other descriptive product materials; manuals; training or training materials; software; websites or system based information; or other appropriate means.
  5. Agents shall participate in continuing education designed to provide current knowledge regarding products, industry issues, and emerging trends.

 Compete Fairly

  1. Engage in fair and active competition in the marketing and sales of insurance products.

The Company and its agents will:

  1. Maintain compliance with the applicable state and federal laws fostering fair competition.
  2. Refrain from disparaging competitors.

Sales involving the replacement of an insurance product, agents will:

  1. The agent shall provide clients with information they need to ascertain whether a replacement is appropriate, including reasons why it may not be appropriate.

 Sell Fairly and Use Clear and Accurate Sales Materials

  1. Advertising and sales material that is designed to lead to sales or solicitation of insurance products should be presented in a manner consistent with the needs of the client.  Such advertising and sales material will be based upon the principles of fair dealing and good faith and will have a sound basis in fact.
  2. Materials presented as part of the sale are clear and understandable in light of the complexity of the product being sold.
  3. Materials are not permitted to be used in the sale of insurance products unless they are reviewed and approved by The Company for compliance with this Code and with applicable laws and regulations related to advertising, unfair trade practices, sales illustrations, and other similar provisions.
  4. Only pre-approved Provider materials can be used.
  5. Appropriately handle and monitor complaints.
  6. Client complaints will be identified, evaluated and handles in compliance with applicable laws and regulations.
  7. Policies and procedures will be maintained, adhered to and designed to reasonably ascertain that client complaint information gathered is analyzed, efforts are made to eliminate their root cause, and that it makes good faith efforts to resolve complaints and disputes.

 Appropriately Handle and Monitor Complaints

  1. Client complaints will be identified, evaluated and handles in compliance with applicable laws and regulations. Materials presented as part of the sale are clear and understandable in light of the complexity of the product being sold.
  2. Policies and procedures will be maintained, adhered to and designed to reasonably ascertain that client complaint information gathered is analyzed, efforts are made to eliminate their root cause, and that it makes good faith efforts to resolve complaints and disputes.

Supervision

The Company is committed to maintaining ethical market conduct and sales practices. Guides, such as this Members Manual are meant to provide guidance and suggestions for a variety of situations but may not be able to address all possible situations that you as an agent may face in your day to day activities. Furthermore, there may be situations where an agent may require supervision or may require some form of monitoring. If you function in the capacity of a supervisor, it is your

responsibility to understand any and all requirements of your role. If The Company or an insurance company believes that an agent has failed to comply with policies, procedures, or established

guidelines one or more of the following steps may be taken:

  1. Training or retraining may be initiated
  2. Agent’s sales may be monitored for a period of time
  3. Compensation may be appropriately adjusted (including moving to “as earned”)
  4. A verbal or written warning may be issued; And/or
  5. The agent’s contract and/or appointment with the insurance company may be suspended or terminated, and/or the agent’s affiliation with The Company may be suspended or terminated.