Code of Ethics

Message from the CEO

Foresters Financial^TM: 150 years of making a difference

From our start in 1874, Foresters has helped to provide families with financial security and protection, while following our larger purpose: enriching family and community well-being. More than a century-and-a-half later, this commitment forms the foundation of who we are and still sets us apart.

As an international fraternal benefit society, Foresters provides life insurance and investment products that empower our members to do more of the good they want to do. Foresters does not have shareholders, but instead exists for its members, reinvesting a portion of profits back into directly supporting them and the communities in which they live.

Foresters is authentically purpose-driven, which defines us at our very core. It is woven into the fabric of who we are — from the work that we do, to the employees we recruit, right through to the customers with whom we do business. It shapes how we act — and especially, how we act when the world isn’t looking.

Every day, in everything that we do, we strive to fulfill our purpose in a way that is ethical and adheres to the highest standards of integrity and professionalism. We are proud of our reputation for fairness and honesty, and we expect everyone associated with Foresters to do the right thing, in the right way, for our members, customers, employees and other stakeholders.

Please review and familiarize yourself with this Code of Ethics and use it to guide you in business conduct and decision-making. If ever you have questions, reach out to your manager or a member of our Executive team to help you arrive at a resolution that is right, fair and is aligned to Foresters values.

The importance of ethics

Foresters is committed to maintaining high ethical standards and complying with all applicable laws. This Code of Ethics (the “Code”) embodies our corporate culture and our values and outlines the principles and practices we believe in and live by. It provides a framework for ethical decision-making as we carry out our day-to-day business at Foresters. Our Code is based on four ethical principles:

• We conduct ourselves with the highest ethical standards of integrity, professionalism, honesty, fairness and respect, in our words, actions, and decisions.
• We act in the best interests of our members and customers.
• We act and comply with the letter and the spirit of applicable laws, regulations, policies and standards.
• We avoid conflicts of interest where possible and disclose conflicts of interest when they arise.

Not maintaining high ethical standards or acting without integrity can seriously harm Foresters, including by damaging its reputation or resulting in fraud, legal issues, and an increase in vulnerability to undue influence, foreign interference, and malicious activity.

How to use the Code

The Code provides principles-based guidance as part of an ethics and compliance framework and is designed to encourage, inspire and reward proper conduct. Everyone associated with Foresters is always expected to be familiar with and know how to access the Code and adhere to its principles.

The Code applies to all directors, officers, employees, representatives, and contract employees of The Independent Order of Foresters and its subsidiaries worldwide (collectively “Foresters”). We expect our member leaders, volunteers, service providers, suppliers and independent contractors to demonstrate good character, and to adhere to the principles and values described in the Code in their dealings and interactions with Foresters or in relation to any business or activity carried out on our behalf.

While the Code outlines our approach to our desired culture and to our ethical business conduct, it isn’t possible to address every possible scenario in one document. For more guidance, employees can refer to the policies referenced throughout the Code and listed in the last chapter. Various local policies and guidelines may also apply.

How to report a breach of the Code

We all play a part in ensuring the Code is applied in our everyday business and that any unethical or illegal conduct is addressed. We encourage reporting of any concerns. This helps us maintain our commitment to high standards of ethics and integrity. We encourage and support employees to ask questions, seek advice and to report known or suspected breaches of the Code. Most importantly, we can feel comfortable to speak up about any issue, concern or breach of the Code in an environment that is free from reprisal or recrimination. Foresters does not tolerate any acts of retaliation against anyone who, in good faith, makes a report of known or suspected unethical or illegal conduct. We make it easy to report a concern or breach, by providing various reporting options. These include:

• Discussing a concern with a manager or senior executive
• Contacting Human Resources, Compliance, Legal or Internal Audit
• Raising the concern with a member of the Board of Directors
• Contacting our EthicsPoint Hotline. You can use this service if you prefer to remain anonymous or if you feel your concern has not been appropriately addressed.

We all have a responsibility to report known or suspected unethical or illegal conduct or breaches of this Code. In addition, threats from suspected undue influence, foreign interference, and malicious activity must be promptly reported. Failure to report within a reasonable period of time is, itself, a breach of this Code.

What happens if I make a report?

Questions and reports are welcome and kept in confidence. We take all reports seriously. They help us clarify appropriate conduct and protect our integrity and reputation.

We investigate all reports of known or suspected unethical conduct in a timely, appropriate and sensitive manner. We may discipline and/or terminate our relationship with anyone who violates this Code or its supporting policies and guidelines. If violating the Code also violates the law, prosecution may also result.

For more guidance, see the following related policies:

• Ethics Reporting/Whistleblower Policy

Our role in an ethical workplace

While many companies have social responsibility pillars, Foresters exists solely to enrich the well-being of our members and customers, their families, and the communities in which they live. We bring our purpose to life in three ways:

• We help members and customers to protect their family’s financial future by providing quality products and services.
• We offer unique member benefits1 that help our members, customers and their families do more of the good they want to do.
• We provide opportunities for community involvement through meaningful Foresters-sponsored events and family activities.

Our reputation for integrity is one of our most valuable assets and protecting it is a responsibility we all share. In achieving our commitment to integrity:

• We are honest, open and trustworthy.
• We treat others with courtesy and respect, even in difficult or emotional situations.
• We value and create a culture which promotes the highest ethical standards.
• We pay attention to how things get done, not just to the end results.
• We demonstrate good character, are open-minded and value the opinions, styles and backgrounds of others.

Ownership of work product

Any work product we create in our roles with Foresters belongs to Foresters and cannot be sold or shared outside of Foresters without express, written permission.

What about outside activities?

Employees are free to participate in outside board, vocational, political, or volunteer activities on their own time. Foresters time or property should not be used to conduct such activities. These activities should not interfere with our ability to meet our responsibilities to Foresters, our members and customers or cause harm to our own, or Foresters, reputation.

Protecting our brand and reputation

Foresters has invested significant resources towards the creation and protection of our name, brand, logos, and other trademarks. Foresters owns these assets, and their use is restricted to legitimate Foresters business purposes and only on such terms and conditions as have been established by Foresters.

When representing Foresters in industry or public settings (e.g., participating in conferences, podcasts, speaking or presenting to individuals and groups, or posting content on-line, such as through blogs or social media), we ensure we are qualified, professional and competent to deliver in a way that enhances our professional reputation and reflects positively on Foresters. If you are planning to speak on behalf of Foresters, you must seek approval in advance from Corporate Communications and/or Compliance, as appropriate.

Media communications

Media inquiries will be handled promptly, appropriately and consistently. Only specifically designated employees can communicate with the media or the general public on behalf of Foresters. All news releases are handled through designated individuals and employees are prohibited from engaging in any communication on behalf of Foresters that is false, misleading or harmful to our reputation or contrary to the Code. Our media contact information can be found on the Newsroom page of foresters.com.

Foresters uses a variety of social media channels, such as Facebook, Instagram and LinkedIn, to engage and communicate with various audiences and share our good works. Designated employees ensure communications made through these channels are consistent with the Code and applicable local policies. Our members, customers, employees and other stakeholders are expected to adhere to the principles of the Code when they post online on behalf of Foresters. Where an employee, member or other stakeholder is communicating online in a personal capacity, they are expected to do so in a manner consistent with the Code and its governing standards. Only those permitted to represent Foresters on social media channels may do so.

For more guidance, see the following related policy:

• Social Media Policy (UK)

Respecting our relationships

Foresters is committed to a culture of collaboration, inclusion, diversity, integrity, equity and mutual respect. We strive to provide and maintain a productive and rewarding workplace. Employees should be treated with dignity and respect and can expect to work in a safe and healthy environment, free from discrimination, harassment, violence, threats and intimidation. Employees are valued and supported to be able to perform to their highest potential.

Our employees are hired, paid, assigned, disciplined or promoted based on ability, experience, performance and qualifications. Foresters is an equal opportunity employer and we do not discriminate against anyone based on race, colour, gender, disability, ethnic or national origin, age, religion or creed, sexual orientation, marital or family status, civil status, pregnancy or other grounds covered by human rights legislation or local regulations.

Any form of workplace violence or harassment will not be tolerated, and we take reasonable steps to both prevent and deal proactively and effectively with any form or workplace violence or harassment when it occurs. If you have any concerns, contact a Human Resources representative.

• Workplace violence involves attempting or using physical force against a worker in the workplace that causes or could cause them physical injury. It also includes making statements or behaving in a way that could reasonably be interpreted as a threat to use physical force against them that could cause them physical injury.
• Workplace harassment involves engaging in workplace conduct that is known, or should reasonably be known,
  to be unwelcome or offensive. This includes conduct, comments, gestures, or contact based on, or related to, race, colour, sex, disability, ethnic or national origin, age, religion or creed, sexual orientation, marital or family status, civil status, pregnancy or other grounds covered by human rights legislation or local workplace-related regulations.
• Sexual harassment is a form of workplace harassment that involves unwelcome sexually oriented comments or conduct based on gender or sexual orientation and is also expressly prohibited.

Serving our members, customers and their communities

Enriching the lives of our members, customers and their communities is integral to Foresters purpose. Our members and customers have placed their trust in us, and we reaffirm that trust every day in everything we do. We act in their best interests and seek opportunities to make a difference in their communities effecting positive, sustainable change.

Fair treatment of customers

The fair treatment of customers is integral to our ethics and culture. We strive to provide products and services that are fair, clear, and meet our members and customers’ needs. We will engage distributors who are appropriately licensed and knowledgeable about the products, benefits or services Foresters offers. We will handle complaints and disputes fairly and professionally. Our advertising, promotional or other materials we provide at the point of sale will be clear, transparent, accurate and fair. Our compensation, commission and incentive structures will be appropriate and encourage good practices.

For more guidance, see the following related policy:

• Fair Treatment of Customers Policy (Canada)

Respecting our partners

Foresters believes that the growth and prosperity of our members, customers and their families is linked to the communities in which they live. We measure our success not only by our financial strength, but also by the positive impact we have on our members, customers, their families and communities.

Providing inspiring volunteer opportunities and building lasting relationships with community partners is an important part of who we are and what makes us different in the marketplace. We treat all community partners with high standards of honesty, fairness and courtesy and continually seek and share feedback so we can improve on the impact we jointly make to meet our – and our partners’ – community investment objectives.

When we participate in our volunteer activities, we adhere to this Code and its principles.

For more guidance, see the following related policies:

• Respect in the Workplace Policy
• Volunteer Code of Ethics
• Substance Abuse and Impairment Policy

Ethical business relationships

Foresters relies on outside vendors and service providers for many types of goods and services – from complex technology providers to office supplies and other business needs. It is essential that we develop and maintain business relationships with integrity, respect and with the highest professional expectations of each other.

Choose suppliers fairly

Foresters chooses suppliers through fair competition based on merit, competitiveness, price, reliability and reputation. Expenditure of Foresters funds must be properly approved prior to purchase, and all expenses must be justifiable business expenses. For procurements, appropriate risk assessments and due diligence must be completed and approved, in accordance with established policies and procedures, prior to the commitment of funds or commencement of service or product delivery.

Understanding conflicts of interest

To act fairly, we must avoid, manage and disclose any actual or perceived conflict of interest. A conflict occurs when our personal interests interfere in any way with the work we do for Foresters or when we take actions or have personal interests that make it difficult for us to perform Foresters work objectively and effectively.

This means that we must not put our own personal interests above Foresters interests or enter into activities which could be in competition or conflict with Foresters business objectives or fraternal purpose. We must also take care to detect, disclose, avoid and mitigate situations that could be perceived as a conflict of interest. Some examples of conflict situations include:

• We do business with individuals who are colleagues, or who become friends or family
• We continue to work with a supplier on behalf of Foresters while also seeking a job with the supplier
• We are involved in a romantic relationship with a co-worker who reports to us
• A family member or friend has a financial interest in a potential supplier
• We are associated with agreements between Foresters and suppliers which might result in personal gain or benefit in any way to us or to a member of our family

In all situations where a colleague, friend or family member has a financial or personal interest in a matter that comes before Foresters, we have a duty to disclose this immediately. In particular, full disclosure must occur before we approve, participate, vote on, or otherwise cause Foresters to enter into any contractual arrangement with a party with whom there could be potential for conflict or the appearance of conflict.

How to avoid a conflict of interest

The best way to avoid a conflict of interest is to fully disclose to a person in a position of authority, such as a manager or executive of Foresters, at the earliest opportunity, any conflict or potential conflicts. This includes updating the Code of Ethics Certification and Disclosure Form.

Foresters expressly prohibits the employment of family members, customers or those who are closely associated together – such as in the case of co-habitation, a romantic or other intimate relationship – when they are in a position to report to one another or influence any decisions regarding the hiring, promotion, performance assessment, supervision, salary review, or termination of one to the other. This policy also applies when individuals are or have become engaged in an outside business relationship, become related or form close relationships after the reporting line was put in place. Relationships such as these, have the potential to cause harm to the business. To ensure complete objectivity, Foresters will encourage one or the other individual to voluntarily transfer or resign from his or her role, or in the absence of such a decision, we will investigate the arrangement, and if it is deemed to be necessary, look for alternative roles for one or both of the employees. Where this cannot be accommodated, it may be appropriate to review the ongoing employment of one or both employees.

Guidelines covering some common situations are included here but it is not possible to anticipate every situation we might encounter. At all times, common sense, integrity, and good judgement should guide us. When in doubt, speak to a representative from Legal, Compliance, Internal Audit and/or Human Resources departments, as appropriate.

Sharing information

We need to develop strong and lasting relationships with our service providers and suppliers and make it as convenient as possible for them to do business with us. To help them achieve their mandates, we often need to share our confidential business plans, objectives, policies and standards.

In keeping our service providers and suppliers informed, we should avoid spreading rumors, speculating, or sharing misleading information. We don’t make promises Foresters cannot keep or take unfair advantage of others. We avoid actions that could be considered manipulative, concealing or abusing information, misrepresenting facts or other unfair dealing practices.

We must also take care not to discuss Foresters business, particularly plans involving major purchases, in public places or where we could be overheard by visiting suppliers or with family, friends, members or customers who may be associated with a supplier or prospective supplier.

Gifts and entertainment

From time to time, we may be offered, or may receive, gifts, favors, benefits or entertainment (“business courtesies”) from suppliers, business associates, or others, such as government officials.

Before accepting any business courtesies or offering the same, we must continuously take care to avoid perceived or actual impropriety. Business courtesies must be avoided altogether or be of nominal value (under $100 in North America; £50 in UK), such as promotional items like pens, hats, notepads or mugs. We may also have an obligation to report or seek pre-approval of gifts and entertainment.

If we are unsure of whether a business courtesy is suitable, we should speak to our manager. Special laws apply to gifts or entertainment when dealing with government officials and is illegal, and even criminal, in some countries. Speak to Legal or Compliance before offering gifts to such individuals.

For more guidance, see the following related policies:

• Procurement Policy
• Third Party Risk Management Policy
• Gifts Policy (UK)

Respecting privacy and confidentiality

We are committed to protecting confidential information – whether about Foresters or our members, customers, employees, colleagues, suppliers and business partners. Protecting the confidentiality of personal information against loss, theft, unauthorized collection, access use or disclosure is critical to the security and confidentiality of assets, communications and information, as well as maintaining our good reputation and the commitment we have made to our stakeholders. Protecting confidential information is everyone’s responsibility.

Confidential information includes, and is not limited to: trade secrets, employee or personnel records, medical records, business plans and proposals, sales forecasts, marketing strategies, client and customer lists, pricing or pricing strategies, construction plans, vendor supply data, new business leads, and information about research and development.

We comply with privacy and security laws and have established policies and standards to ensure we treat confidential information with a high standard of care. We are transparent about how we collect, use or share personal information and do so only for legitimate business purposes or with consent, and as required by law.

Handling Foresters information

We collect and use a great deal of information about our members, customers, employees and others with whom we develop relationships. This information is vital to our success and must be protected at all times. Any disclosure of this personal information, including to vendors, producers, advisors, or others, must be in compliance with Foresters Privacy Policy and be limited to those who have a need for, or the legal right to, the information.

Protecting personal information in Foresters possession or control is critically important and everyone’s responsibility.  Improper disclosure of information can have very serious consequences – potentially resulting in legal action against Foresters or damage to Foresters reputation.

Even after we are no longer associated with Foresters, we have a duty to protect confidential information and must return any files, records or other Foresters information in our personal possession when our employment ends.

We must safeguard confidential and personal information, whether in paper or electronic form, from unauthorized disclosure. Records and files of Foresters directors or employees can only be accessed for a legitimate business purpose and must be kept confidential.

We should be especially careful when communicating through email, social media or the Internet as inadvertent disclosure of proprietary or confidential information can put us and others at risk.

Foresters has established various policies and standards to protect individual privacy and confidential business information.  As part of this effort, employees are responsible for ensuring their workplaces and remote workplaces (e.g., desks, offices, and common areas) do not provide inadvertent access to confidential or personal information, in paper or electronic form.

Personal information

The personal information we handle is protected by law and is confidential. We only provide access to personal information to individuals within Foresters when such access is required to perform their jobs. Personal information about members, customers and employees is only shared or disclosed outside of Foresters for legitimate business purposes, with consent or as required by law.

For more guidance, see the following related policies:

• Enterprise Privacy Statement and Privacy policies
• Information Security Policies and Standards
• Records Management Policy
• Clean Desk Policy

Ethical record keeping

Foresters is committed to maintaining accurate and reliable records to meet our legal and financial obligations and to manage our business. Records include all paper and electronic documents and transactions pertaining to our business.

All financial transactions and records must be properly and accurately recorded and must not be altered, concealed or falsified. Our books and records should accurately reflect all business transactions and undisclosed or unrecorded revenue, expenses, assets or liabilities are prohibited.

Employees must comply with established policies, guidelines and retention requirements to satisfy applicable business, financial, legal and regulatory requirements.

Respecting copyrights and licenses

Much of the information, materials or assets we use in the course of our involvement with Foresters are protected by copyright laws or subject to licensing requirements. This includes computer software, books, trade journals and magazines. Intellectual property such as presentations, slides, training materials, or work product of suppliers, consultants or others, could also be copyrighted. It is illegal to reproduce, distribute or alter copyrighted material without proper authorization.

Employees must not use the output of any artificial intelligence (AI) system to represent activity they supposedly undertook. Improperly using output of AI could lead to legal, ethical, plagiarism and copyright issues.

In addition, we must also take care to avoid installing or using software or other materials that are subject to licensing agreements.

For more guidance, see the following related policies:

• Records Management Policy
• Privacy and Data Protection policies
• Employee Privacy Policy
• Anti-Fraud Policy
• Regulatory Compliance Management Policy
• Artificial Intelligence Acceptable Use Policy
• Compliance Manual (UK)
• Internal Control Policy
• Financial Crime Manual (UK)

Promoting a strong risk management culture

Our role in managing risks

We are committed to regularly identifying, assessing and managing our key risks as appropriate, and encouraging transparency around those risks to ensure that good business decisions result. Effective risk management is critical to our long- term success.

Our risk philosophy is based on the premise that we accept and manage risks in accordance with our corporate strategy and business objectives, and thereby create value for our members, customers and other stakeholders. Our risk management culture is supported by a strong tone from the top that promotes appropriate conduct. It starts with our Board of Directors and cascades through our Chief Executive Officer, our business leaders and our employees.

At Foresters, we all play an important role in managing our risks.

• We will understand the risks we manage and those which impact our members, customers and other stakeholders.
• We will work together to achieve business objectives while operating within our risk appetite and risk tolerances.
• We will embed risk management within our business activities, involve the right stakeholders at the right time, and reward individuals for taking the right risks in an informed manner.
• We are transparent about risks and outcomes such that we can all learn from our experiences without fear of reprisal.

Ensuring financial integrity and maintaining internal controls

Maintaining appropriate controls

We are committed to maintaining a robust internal control framework. This helps us achieve our business objectives, mitigate risks and meet our ethical obligations to our members, customers and other stakeholders. We are all responsible for Foresters internal controls and must understand how they relate to our roles and responsibilities. We will:

• Understand our department’s objectives and how our role contributes to achieving them,
• Establish and maintain appropriate controls to achieve our objectives and mitigate associated risks,
• Be aware of changes in our business affecting our role, and adapt our control activities appropriately to address risks, and
• Regularly monitor the effectiveness of internal controls for which we are responsible and resolve related problems on a timely basis.

For more guidance, speak to your manager or refer to our Internal Control Policy.

Handling money

When handling money, or instruments representing money, in the course of conducting Foresters business, we must understand that we are doing so ‘in trust’. All funds collected on behalf of Foresters or our members and customers must be properly receipted and expeditiously forwarded to appropriate authorities within Foresters. Under no circumstances shall anyone associated with Foresters make any personal or other use of such funds. Everyone covered under the Code must know and respect the difference between our own personal money, members’ or customers’ funds and Foresters funds. Co-mingling of funds, (placing together business and/or member or other customer funds and/or personal funds) is expressly prohibited. All transactions involving the transfer of funds must be complete, handled accurately and in a timely manner.

Deterring fraud

Foresters does not tolerate fraudulent activity in our business or fraternal activities. Fraud impacts not only the stability of Foresters but also our reputation in the industry and with our members, customers and their communities. Fraud is an intentional dishonest act or omission made for personal or corporate gain. Some examples of fraudulent acts include:

• Identity theft
• Falsification of financial and other records
• Theft
• Forgery
• Misuse of Foresters assets
• False or fictitious claims

Avoiding corruption and bribery

When negotiating or entering into contracts or other arrangements with individuals and firms for professional services or products, we must be guided solely by the merits of the arrangement to provide benefit for Foresters and our members and customers and avoid any conduct that influences, or is perceived to influence, fair judgement.

Foresters is committed to acting with honesty, integrity and transparency. We conduct our business in accordance with our purpose and values. Offering or accepting any item that could be construed as a bribe or inducement is prohibited. Bribery means giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so. This includes seeking to influence a decision-maker by giving an extra benefit over and above what can legitimately be offered as part of a tender process. Bribery is a criminal offence in most countries. Foresters, our directors, officers and employees can face serious consequences if found in violation of bribery laws.

In conducting our business, we must not be influenced, or attempt to influence, by, gifts, favours, inducements, rebates, or other personal benefits. Similarly, we must never give or promise gifts, favours or personal benefits to stakeholders from whom we require support or receive oversight, such as government agencies or related personnel.

Unless authorized in writing by management, never accept cash or its equivalent, or a material item of value, in connection with the negotiation of a business transaction.

Detecting money laundering and terrorist financing

Like all financial institutions, Foresters is required by law to have policies and procedures in place to prevent, detect and report suspected money laundering and terrorist financing activities.

Financial institutions may become targets of terrorists or criminals intending to launder money or fund terrorist or other criminal activities. Money laundering transforms ‘dirty’ money resulting from criminal activity into ’clean’ money so that its original source is difficult to trace. Terrorist financing uses money to fund terrorism or terrorist groups.

We are committed to ensuring that we properly identify our customers and report any suspicious payments, transactions or other suspicious activities, as required by law. All employees are required to complete anti-money laundering and anti-terrorism funding training and to comply with all relevant programs, policies and procedures.

For more guidance, see the following related policies:

• Risk Management Policy
• Internal Control Policy
• Anti-Money Laundering and Anti-Terrorism Financing Policy
• Anti-Fraud Policy
• Regulatory Compliance Management Policy
• Compliance Manual (UK)
• Financial Crime Manual (UK)

Protecting our assets

Using technology appropriately

Foresters technologies and business systems are critical business assets that we are committed to using appropriately. Foresters assets – business machines, equipment, vehicles, buildings, business and communication systems such as, telephones, mobile devices, computers, photocopiers, corporate credit and calling cards, e-mail, instant messaging, voicemail, traditional mail systems, for example – are to be used primarily for Foresters business.

• This does not prevent the occasional, minimal personal use of such assets, if appropriately disclosed and approved, and if such use doesn’t conflict with this Code or applicable policies. Foresters technologies and business systems are Foresters property and we cannot expect personal privacy for communications that we send, receive, or store on these systems.

Personal charges

When personal charges beyond a minimal level are incurred using Foresters assets (e.g. couriers, mail, long-distance telephone, office supplies, and printing services) we are required to report and reimburse such amounts to Foresters immediately.

For more guidance, see the following related policies:

• Information Security Policy and related Standards
• Employee Privacy Policy
• Computer Usage Policy
• Computer Software Use Policy (North America)

Ethics and the law

Foresters engages various professionals in the course of our business, serving our members and other customers, and sponsoring or participating in community activities. In doing so, we are committed to conducting business with integrity and in full compliance with both the letter and spirit of all the laws and regulations that govern our business.

Many of us must also abide by professional or regulatory guidelines or standards that govern our conduct. For example, actuarial, accounting, audit, investment, or legal staff must comply with industry standards of professionalism, ethics and conduct. Similarly, investment professionals are required to comply with investment policies and an industry-accepted code of conduct.

Where the Code and applicable standards are inconsistent or in conflict, we must always abide by the higher standard.

Know and comply with the law

We have a responsibility to know and comply with the laws that apply to our business. We also have a duty to report others if we observe or become aware of violations of laws or unethical conduct. Specifically, we must not personally engage in, nor allow others to engage in fraud; theft; misappropriation of funds or organizational time; supplies; data; documentation, computer programs or computer time; receipt or payment of kickbacks or rebates; forgery or falsification of records or documents; and unauthorized modification or manipulation of computer programs or documents; among others.

Verbal or physical assault, possession or use of a weapon on any of Foresters premises and disregard of property or safety standards are all expressly prohibited. No one covered under this Code shall possess or use alcohol, recreational cannabis or illegal drugs while at work, including remote work, and while conducting Foresters business or while driving or riding as a passenger in any Foresters owned or rented vehicle. While alcohol may be served at some Foresters corporate, sales, branch, or community events, we are all individually responsible for ensuring that our consumption is moderate, and we remain professional at all times.

Employees must comply with applicable laws that forbid or restrict the use of mobile devices and cellular phones while driving. For example, if we are driving to work and wish to call and report a delay in our arrival time, we should do so in a way that is legal in our jurisdiction and does not present a risk of an accident involving you or others. Depending on local laws, this could include using a hands-free device or by pulling over safely to the side of the road.

Putting the Code into practice

Completing the Code of Ethics Certification and Disclosure Form

This Code should be consulted regularly as a guide to ethical business conduct and decision-making and, at least once a year, we are all expected to review the document in its entirety and to complete a Code of Ethics Certification and Disclosure form.

Any time our circumstances change so that they affect our business relationship with Foresters, we must disclose this by completing an updated Code of Ethics Certification and Disclosure form.

Refusal to sign and submit this form when requested, providing false statements, or deliberately withholding required information, will result in disciplinary action and possible dismissal.

How to get in touch or report concerns

To discuss questions or concerns or to report suspected breaches of the Code, we can choose among several internal reporting options: Raise the matter with a Foresters manager or executive:

Supporting policies

Policies that support the Code and/or which have been referred to within the Code include:

  Global policies

There may be other local policies, guidelines, processes or procedures that apply in addition to the above policies. Check your local intranet or speak to your manager or to Compliance.