Leading with integrity and accountability

Code of Conduct

Table of Contents
Integrity Starts with Me
2 A Message from the CEO

A Culture of Integrity
3 Values and Principles
4 Rules to Remember
4

RGA Resources

5 Code of Conduct Introduction
6 Speak-Up
7 Non-Retaliation

Acting with Integrity
8 Human and Labor Rights
9 Work Safety and Health
10 Insider Trading
11 Conflicts of Interest
12 Antitrust and Fair Competition
13 Economic Sanctions
14 Bribery and Corruption
15 Anti-Fraud
16 Gifts and Entertainment
17 Protection of RGA Assets
18 Statements and Records
Code of Conduct

1

A Message from Tony Cheng
Dear colleagues,
RGA became an industry leader by being an innovative and trustworthy partner. Our clients know thatthey can count on RGA to do the right thing, keep our promises, and deliver on our commitments to all of
our stakeholders. We have to earn that reputation every day, with every client, and in every interaction
because in our industry there can be no success without trust, and no growth without a solid foundationof shared values and behaviors.
At RGA, we are guided by our values: Accountable, Client-Centric, Innovative, Inclusive, Purpose-Driven,and Trustworthy. We must be vigilant in protecting RGA’s reputation and securing our success by
incorporating these values into how we conduct business and how we treat each other.
The principles and rules contained in this Code of Conduct are informed by these values and serve as
guidelines for operating according to the highest ethical standards. Each of us is a guardian of RGA’s
reputation; therefore, each of us must take personal responsibility and use our best judgment in all
business endeavors and relationships. Never underestimate the importance of your actions and how theyaffect you, your colleagues, and RGA.
For more than 50 years, RGA has been building a legacy of trust. By staying true to our values andpursuing company goals honestly and ethically, we can continue that legacy into the future. Through thisculture of integrity, honesty, and cooperation, everyone contributes to achieving RGA’s purpose of
making financial protection accessible to all.

Tony Cheng
President and CEO
Reinsurance Group of America, Inc.

Code of Conduct

2

Values and Principles
Rule to Remember >> RGA’s values define who we are.

Our Values
Accountable
We demonstrate commitment and responsibility
to our clients, colleagues, communities, andother stakeholders.

Purpose Driven
We pursue our purpose by boldly striving forsuperior organizational performance and personallearning and development in all situations.

Client-Centric
We place client needs at the center of everything we
do as an organization.

Trustworthy
We demonstrate integrity by keeping ourcommitments and modeling ethical behavior at all
times.

Innovative

We are curious and creative, challenging the status
quo to develop inventive solutions that optimize
performance.

Inclusive

We build a safe and welcoming environment where
diverse viewpoints, resources, and expertise are
actively shared and sought. We actively collaborate
in pursuit of common goals.

Code of Conduct

3

Rules to Remember
The Rules to Remember are expectations that expand upon our Values and outline the standards by which we expect RGA’s business operations to be conducted. The RGA
Code of Conduct does not address all workplace conduct; thus, workforce members are expected to consult other applicable RGA policies and guidelines that may provide
additional guidance or address topics not covered by the Code of Conduct.
Here is a list of Rules to Remember featured throughout the Code of Conduct. For additional guidance, check out the Policy Portal intranet site.

Speak-Up

Workforce members have a responsibility to
speak up and voice any concerns.

Non-Retaliation

Workforce members can raise concerns without
fear of retaliation, direct or indirect.

Human and Labor Rights

RGA maintains an inclusive work environment
where all workforce members are treated with
dignity and respect.

Workplace Safety and Health
RGA commits to providing a safe and healthy
environment in the workplace.

Insider Trading

RGA prohibits workforce members from using or
sharing material, non-public information about
RGA and other companies.

Conflicts of Interest

Workforce members must avoid all real or
potential conflicts between their own interests andthose of RGA or its clients.

Antitrust and Fair Competition

RGA competes legally and ethically by following
all antitrust and competition laws.

Economic Sanctions

Workforce members must ensure that RGA is notpart of any RGA financial transactions involving a
blocked entity.

Bribery and Corruption

Workforce members should never allow
acts of bribery or corruption to influencebusiness decisions made on behalf of
RGA.

Anti-Fraud

Workforce members have a responsibility to reportsuspected incidents of fraud and to conduct theirwork in such a way as to prevent fraud fromoccurring in the workplace.

Gifts and Entertainment

Workforce members must not give or receive any
inappropriate gifts or entertainment.

Protection of RGA Assets

Workforce members have a responsibility to protect
RGA’s physical assets as well as the personal andsensitive data RGA hosts on its systems.

Statements and Records

Workforce members are honest and accurate incommunications and recordkeeping on behalf of RGA.

RGA Resources
At times, we may encounter situations in which the right choice is not clear. If you need to ask a question or speak up about a concern, your direct manager orsupervisor is likely the best resource to speak to because he or she knows your business function, team, and situation.
However, you are always encouraged to contact any of the following resources to seek guidance or report your concerns:
 RGA’s Speak-Up Hotline
 Global Human Resources Global Ethics and Compliance
Code of Conduct Global Risk Services
 RGA Legal Counsel
 Global Information Technology

 Global Internal Audit Global Security and Privacy Office4

Code of Conduct Introduction
Rule to Remember >> Any individual representing or acting on behalf of RGA must follow RGA’s Code of Conduct.

RGA Code of Conduct

Your RoleThe Role of Our Leaders• The Code of Conduct applies globally to all• RGA expects you to read and gain a basic
understanding of the ethical standards describedin the Code of Conduct.

Leaders include any person(s) having
responsibility for achieving the business objectivesof RGA and the authority to establish strategies
and make decisions designed to reach thoseobjectives.

workforce members throughout ReinsuranceGroup of America, Incorporated, and all of its
subsidiaries and affiliates (RGA). Workforce
members include any regular or temporary
employee, contingent worker, contractor,
consultant, or individuals representing or acting on
behalf of RGA.

• The essential elements of professional

ethical conduct include honesty, fairness, andrespect for not only the individual but also
respect for property.

• RGA’s Code of Conduct translates theseessential elements of ethical conduct into a setof practical rules and standards to serve as a
guide for conducting business on RGA’s behalf.

• RGA’s Code of Conduct is based on our corevalues and principles and serves as afoundation for RGA policies, standards, andprocedures.

• Because the Code of Conduct cannot cover

all situations, the rules and standards outlined
are not a substitute for sound judgment andpersonal accountability.

• The Code of Conduct supplements, but does

not replace, any applicable RGA policies,
standards, or procedures that are in place or
implemented in the future.

Code of Conduct• You must comply with the Code of Conduct,
RGA policies, and any applicable laws of thecountries in which RGA operates.
• You are responsible for conducting yourself
with the highest degree of integrity at all
locations and situations where RGA business isconducted as well as all company-sponsored
events.
• The Code of Conduct cannot cover every
possible situation, which is why RGA relies on
you to use good judgment and promptly speak up
when questions or concerns arise.
• If during the course of your employment with
RGA, you become aware of or suspect aviolation of the Code of Conduct, RGA policies,
or applicable laws, you must report it to yourdirect supervisor, a member of the Global Ethics
and Compliance office, or through the Speak-Up
Hotline.

Leaders must not only behave ethically but also takeaffirmative steps to influence and encourage their direct
reports to do the same.
As an RGA leader, you have the following
additional responsibilities:• Reinforce the Code of Conduct by complying withall standards of the Code of Conduct, applicablelaws or regulations, and RGA policies.
• Encourage a culture of ethical compliance throughleadership that demonstrates the highest
professional standards at RGA.
• Monitor your direct reports’ compliance with
the Code of Conduct and hold themaccountable to RGA’s high ethical standards
and expectations.
• Champion the Code of Conduct and RGA
policies and serve as a resource for direct reports
when they have questions or require guidance.
• Take a stand against any form of retaliation.

5

Speak Up
Rule to Remember >> Workforce members have a responsibility to speak up and voice any concerns.

Our PolicyYour Role• RGA’s reputation for integrity is one of our• If you witness or suspect illegal or unethicalbehavior involving RGA activities or need help
making an ethical decision, you have multiple
resources available at RGA, including:most important assets. Protecting that
reputation is the responsibility and obligation of
every workforce member by speaking up andreporting an issue, whether observed orsuspected.

• Regardless of which resource you contact

to report an issue, RGA will handle theconcern appropriately and promptly.

• RGA maintains a strict non-retaliation policy

for factual issues raised in good faith.

• RGA maintains compliance with applicable

whistleblower laws in the jurisdictions in which it
operates.

• Depending on local privacy and whistleblower

laws in individual countries, the Speak-Up
Hotline may not always be permitted to allow
anonymity or may limit specific topics that can bereported to accounting, financial, auditing, andbribery matters only.

- Direct Managers or Supervisors- Human Resources Department- Global Ethics and Compliance- RGA Legal Counsel• When you are not comfortable seeking
advice or guidance from your direct supervisor
or another leader, you have the option to use the
Speak-Up Hotline, which is managed by a third
party.
• Visit the Speak-Up Hotline website formore information about reporting an issue.
• What can you report? Examples include, but
are not limited, to the following:- Discrimination or Harassment- Misstatement of Financial or Non-

Financial Records- Bribery, Corruption, or Kickbacks- Conflicts of Interest- Violation of applicable law, rule, regulation,

What You Should Know
Question: What does it mean that my
Speak-Up Hotline report will be kept
confidential?
Answer: Regardless of whether you choose
to provide your name, the Speak-Up Hotline
and RGA will only disclose the information
you provide on a strictly “need-to-know”
basis.
If you request anonymity, RGA will not reveal
your identity and will take all reasonable steps
in any investigation to reduce the risk of you
being identified
The department assigned to investigate theissue will receive the reported information,and if you have provided your name, may
contact you for additional information.
The department may also share information
with management and other appropriate
resources, as necessary. Moreover, RGA
may be required to provide information inlitigation or regulatory proceedings.

RGA Policies, or the Code of Conduct• When you contact the Speak-Up Hotline, it
is critical to provide as many details as
possible (e.g., who, what, when, where). The
more information you can provide, the more
efficient any investigation will be.

Code of Conduct6

Non-Retaliation
Rule to Remember >> Workforce members can raise concerns without fear of retaliation, direct or indirect.

Our PolicyYour Role• RGA values and relies on you to identify• As a reminder, reports of suspectedviolations of the Code of Conduct, RGA
policies, or laws and regulations are treatedseriously and promptly reviewed.

potential issues and raise concerns that may
need to be addressed. RGA does not tolerate actsof retaliation against any person who reports anissue honestly and in good faith.

• RGA’s commitment to non-retaliation

assures you that raising concerns, reporting
misconduct, or cooperating in any investigation
will not result in suffering adverse
consequences.

• Regardless of your role at RGA, if you
suspect retaliation is occurring or has
occurred against you or others, you must
contact the local Human Resources
representative, Global Ethics and Compliance,
or RGA Legal Counsel.

• RGA will not tolerate retaliation in any form,• Should you discover the identity of anindividual who spoke up, or is involved in an
investigation, you must respect their need for
confidentiality.

• Parties involved in the investigation of a

• You are expected to cooperate in internal
investigations, audits, or directions from an RGA
staff member involved with a lawsuit orgovernmental investigative proceeding.

at any level of the organization. Retaliatory
behavior perpetuates an environment of fearand places you at risk for disciplinary action.
suspected violation will make every
reasonable effort to maintain yourconfidentiality.

Code of Conduct

What You Should Know
Question: What is considered an act of retaliation?
Answer: Retaliation includes threatening or
taking actions such as termination of
employment, denial of promotion, or negative
performance assessments resulting from aworkforce member raising an issue orreporting misconduct.

An act of retaliation can also include thedenial of favorable assignments or
educational opportunities, being excluded
from meetings, or being the subject ofnegative comments and rumors.
RGA does not tolerate retaliation in any form.

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Human and Labor Rights
Rule to Remember >> RGA maintains an inclusive work environment where all workforce members are treated with dignity and respect.

Our PolicyYour Role

What You Should Know

• RGA recognizes the importance of
maintaining and promoting fundamental
human rights everywhere we operate and do
business.

• Create a positive work environment by
never engaging in any act of harassment,
bullying, or discrimination against aworkforce member.

• RGA complies with all applicable employment
and labor laws, including those related tocompensation, hiring, hours worked, and working
conditions, as well as laws prohibiting the use offorced and compulsory labor, or any form of humantrafficking.

• Conduct yourself in an appropriate,
professional manner in all dealings with othersin the workplace.

Sexual harassment includes verbal, visual, or
physical conduct of a sexual nature that is
unwelcome and makes someone feel
uncomfortable. This may include, but is not limited
to, the following:• RGA provides equal employment
opportunities by not discriminating based on
race, color, religion, age, gender, gender identity
or expression, sexual orientation, genetic
information, marital status, national origin,ancestry, disability, medical condition, veteranstatus, or any characteristic protected by law.
• RGA does not tolerate harassment or bullying
in any form. Acts of harassment and intimidation
which create a threatening, hostile, or offensive
environment are prohibited, whether in physical,
verbal, or written form (e.g., email, text messages,
and social media posts).
• RGA has zero-tolerance for retaliation against
a workforce member who filed a complaint, or
reported suspected or actual misconduct, or
participated in an investigation.

Code of Conduct• Value all individuals in our diverse
workforce and recognize the importance ofunderstanding, appreciating, and embracing
individual differences.
• Recruit, hire, compensate, and award
promotions based on the requirements of the roleand the individual’s qualifications, relevant job
performance, experience, ethical conduct, andother role-related factors.
• Be thoughtful and sensitive to how others inyour work environment might perceive youractions and comments.
• Be vigilant in recognizing signs that others
may be experiencing harassment or
discrimination. If you or someone else is the
subject of any bullying, discrimination, or
harassment, contact your Human Resources
representative or call the Speak-Up Hotline
immediately.

• Repeated offensive sexual advances, flirtations,or propositions• Sexually oriented jokes, pictures, texts, oremail messages• Display of sexually suggestive picturesor pornography in the workplace

Question: A co-worker frequently makescomments about my appearance that make me
uncomfortable. I have asked this individual tostop on more than one occasion, but thecomments continue. What can I do about it?
Answer: Harassment is not always obvious anddoes not require intent to offend. Inappropriate
conduct meant as a joke or compliment canlead or contribute to harassment. You can– and should – report this conduct to yourdirect supervisor, another leader, or your local
Human Resources representative. If you feel
uncomfortable speaking about this topic to thoseresources, you can always call or report thisonline to the Speak-Up Hotline.

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Workplace Safety and Health
Rule to Remember >> RGA commits to providing a safe and healthy environment in the workplace.

Our PolicyYour Role

What You Should Know

• RGA fosters a work environment that is free ofsafety hazards and promotes the health andsafety of all workforce members and visitors, aswell as the communities where we work.

• Conduct your business for RGA in a sober andclear-headed manner and never under the
influence of alcohol or illegal drugs.

Weapons include, but are not limited to,the following:• RGA does not tolerate any workplace violence
committed by or against workforce members. You
are prohibited from making threats or engaging inviolent activities in the workplace.
• RGA prohibits the unlawful sale,possession, purchase, transfer, or use ofillegal drugs or controlled substances on
RGA premises.
• RGA may permit the controlled serving anddrinking of alcoholic beverages at RGAsponsored functions, which may take place offsite
or be scheduled after business hours during theweek or weekends.
• RGA shall investigate all reported violations
and will disclose information obtained to others
only on a need-to-know basis. At the conclusionof the investigation, RGA will take appropriate
corrective action.

• Follow all health, safety, and security-related
policies, procedures, and applicable laws or
regulations to keep the RGA work environment
safe.
• Use good judgment and maintain professional
conduct during instances where alcoholic
beverages are served at RGA-sponsoredfunctions as this does not constitute an excuse forunprofessional behavior or conduct.
• You are responsible for understanding yourown alcohol tolerance level and managing yourown consumption at company events.
• You should never engage in the following,
which are examples of prohibited conduct:- Causing physical injury to another person- Communicating threats of potential violence- Displaying aggressive or hostile behavior- Making unwanted sexual advances- Bringing a weapon onto RGA property or

possessing a weapon while conducting
business on behalf of RGA.

• A firearm or any device from which a projectile
may be fired by an explosive• Any real or simulated firearm operated by gas
or compressed air• A knife or any instrument that can be used
as a weapon or poses a reasonable risk of
injury• Any other weapon which is readily capable ofsevere or lethal harm
Question: I suspect that a fellow workforce
member occasionally comes to work drunk andmay be drinking on the job. I am concerned forthis co-worker’s health and safety. What can I
do?
Answer: You should consult with your directsupervisor, who will take the correct steps to
involve the right professionals to address thesituation. If you are not comfortable discussing thematter with your supervisor, contact anotherleader, your Human Resources representative, or
the Speak-Up Hotline.

• Reporting is the key to enforcement. Without
knowledge, there is little RGA can do toinvestigate such actions. Any suspected orwitnessed acts of violence or substance abuse in
the workplace must be immediately reported to a
direct supervisor.
Code of Conduct9Insider Trading
Rule to Remember >> RGA prohibits workforce members from using or sharing material, non-public information about RGA, and other companies
with which RGA does business.

Our PolicyYour Role

What You Should Know

• In the course of your work at RGA, you may
encounter “inside information,” which ismaterial, non-public information about RGA, suchas revenues, earnings, acquisition or divestitureplans, new products, or other significant
developments and similar sensitive information
about other companies with which RGA does
business.

• Do not disclose material, non-public
information. Such information must be kept
confidential to prevent potential penalties andreputational risks to RGA.

What is Material and Non-Public Information?

• As a publicly-traded company, specific laws
govern how RGA announces its financial results
and other significant developments. Those lawsalso limit how that information can be used or
shared before it is made available to the public.
• Laws, regulations, and RGA policies also
prohibit you from buying, selling, orsuggesting to others that they buy or sell RGA
securities, or the securities ofany other company with which RGA does business,with knowledge of non-public information.
• Consequences of these violations are severe,
including termination of employment, civil or
criminal penalties for you or RGA, and irreparable
damage to our reputation and public trust in ourcompany.

Code of Conduct• Never buy or sell securities when you areaware of material, non-public information. Such
conduct is called “insider trading” and issubject to federal, state, and foreign securities
laws, as well as RGA policies.

• “Material information” generally is defined
as information that:- A reasonable investor is substantially likely toconsider important in making an investment
decision to buy, hold, or sell securities.

- A reasonable investor will view as

significantly altering the “total mix”
of information made available.

• Under no circumstances should you
discuss trades or “tip” others to trade if you
are aware of the material, non-public
information about RGA, or another company
with which RGA does business.

• Information is “non-public” until it has beeneffectively communicated to the marketplace.
One must be able to point to some facts toshow that the information is widely
disseminated.

• If subject to a blackout period, do not trade
RGA securities until RGA lifts the restriction. If a
broker inadvertently buys or sells on your behalf
during the blackout period, you must immediately
report it to RGA Legal Counsel.

• If you inadvertently disclose material, nonpublic information to a person inside or outside
RGA who is not obligated to keep theinformation confidential, you must immediately
report it to RGA Legal Counsel.

10Conflicts of Interest
Rule to Remember >> Workforce members must avoid all real or potential conflicts between their own interests and those of RGA or its clients.

Our PolicyYour Role• RGA prohibits undisclosed conflicts ofinterest or even the appearance of a conflict ofinterest. Our goal is to avoid any relationship,
influence, or activity that might impair or appear
to reduce our ability to make objective and fairdecisions in conducting our business.

• You are required to disclose actual or potential
conflicts of interest to RGA, and you should
remove yourself from making any decisions thatmight be affected by the conflict.

• A conflict of interest may occur when personal
interests or activities conflict or appear toconflict with our judgment or responsibility to
RGA. Or when we use our position with RGA orinformation, we have acquired during employment,
in a way that creates a conflict between ourinterests and the interests of RGA.
• Even the appearance of a conflict of interest
can cause harm to RGA’s reputation. The
appearance of conflict occurs whenever yourinterests could be questioned as potentiallyaffecting your judgment and conflicting with
RGA’s interests.

Code of Conduct• Avoid situations where your loyalty to RGA
could be questioned because of outside interests.
• You must consistently exercise sound,independent judgment, and act in the bestinterest of RGA.
• Never put yourself in a position whereclose personal or family relationships could
influence decision-making or actions.
• Having your own business or other jobs is
acceptable if these activities do not interfere withyour job responsibilities or performance, and do
not compete with RGA’s interests.

What You Should Know
Question: A current RGA third-party vendor
offers a bonus for referring one of its
contractors for a position that would not directly
report to you. Would a referral of the contractor
create a conflict of interest?
Answer: Yes, such a referral situation involving
a vendor’s contractor may cause the appearanceof placing your personal financial interests aheadof RGA’s interests.

Question: My sister recently took a job with avendor that RGA utilizes. What should I do?
Answer: It is always important to disclose apotential conflict of interest as soon as you
become aware of the situation. The Global
Ethics and Compliance team will evaluate
potential conflicts and provide advice on how
best to resolve an issue should it be determinedan actual conflict of interest exists. You should
contact your manager or the Global Complianceand Ethics office to start this process.

11

Antitrust and Fair Competition
Rule to Remember >> RGA competes legally and ethically by following all antitrust and competition laws.

Our PolicyYour Role

What You Should Know

• RGA’s dealings with customers andcompetitors must be based on honest, legal, andfair practices to uphold our reputation for integrity.

• Be aggressive but fair in competition bycomplying with all laws and regulations thatgovern our competitive conduct.

What Is Antitrust Law?

• RGA must not partner with competingcompanies to set terms offered to customers or
purposefully manipulate prices for services or
products.

• Fully honor your commitments to ourcustomers, treat all customers fairly, and ensure
any provided services represent appropriate
value.

• Noncompliance with state, federal, andinternational antitrust or fair competition
laws may result in severe legal penalties for
RGA and criminal charges for the parties
involved.

• Gather appropriate information about RGA’s
competitors by only using channels throughwhich information is publicly available.

Question: Can I pretend to be a customer
to get pricing information from RGA’s
competitors?

• Never make any false or misleading
advertising claims, or any misrepresentations
or other kindsof statements that might create unreasonable
expectations, and do not make any untruthful or
misleading statements about our competitors or
their products or services.

Answer: No. Obtaining information about
a competitor by misrepresenting youridentity or by inducing an employee of thecompetitor or a third party to divulge
confidential information is inappropriate.

• Advertising is considered deceptive if it
contains an untrue or misleading statement, oromits information resulting in content that is likely
to mislead clients.
• Advertising or business practices are
considered unfair if they cause or are likely tocause financial or reputational harm.

Code of Conduct• Report any suspicious activities that may
not comply with RGA’s fair competition
policies or applicable laws and regulations to
RGA Legal Counsel.

• Antitrust Law is a collection of state, federal, andinternational government laws that regulates the
conduct and organization of businesscorporations, generally to promote fair competition
for the benefit of consumers.

Gathering information about ourcompetitors is a legitimate businessactivity when done lawfully and ethically.

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Economic Sanctions
Rule to Remember >> Workforce members must not facilitate any RGA financial transactions involving a blocked entity.

Our PolicyYour Role

What You Should Know

• RGA and all RGA operations worldwide• Comply fully with applicable economic
sanction laws, regulations, and government
guidance, including local laws in countries inwhich RGA operates.

What is OFAC?

must comply with the U.S. Office of Foreign
Assets Control (OFAC) economic sanctions
program.

• RGA is firmly committed to complying withOFAC and all applicable local economic
sanction laws, regulations and government
guidance, and to preventing the participation inor facilitation of financial transactions involving
blocked entities.

• Do not conduct business with third-party
vendors that are blocked under any
applicable economic sanctions program.

• Depending on where a particular RGA• Do not conduct business with, reinsure
policies, or pay claims that relate to policy
owners, insureds, or beneficiaries that are blocked
under any applicable economic sanctions program.

• Failure to comply with economic sanctions• While you may never be in the position toviolate economic sanction laws, you should be
alert for irregularities or “red flags” in the payment
process, including but not limited to, the following:

operation is based, it may also be subject to thecompliance requirements of a local economic
sanctions program.
programs could result in severe criminal andcivil penalties for RGA and its workforce
members, including fines and imprisonment. It
would damage RGA’s good name andreputation.

- Attempts to make substantial payments in cash
- Payments made by a party who has notbeen involved in the RGA business
contract- Requests to pay more than listed in theagreement- Payments made in currencies other thanthose specified in the contract- Payments received from an unusual

source or non-business related account

Code of Conduct• The Office of Foreign Assets Control (“OFAC”)
administers and enforces economic sanctions
against individuals, entities, companies, andcountries, including terrorists and narcotics
traffickers.
• The sanctions can be either comprehensive or
selective in nature. Such sanctions include
blocking assets and implementing trade
restrictions to achieve foreign policy and national
security goals.
• RGA utilizes the list of blocked governments,
persons, entities, and companies maintained by
OFAC and other sanctions programs.

.

Question: A foreign organization recently
contacted your department to arrange for thepurchase of certain services. The organizationis headquartered in a country in which RGA has
never done business. What should yourdepartment do?
Answer: Before discussing business with thisorganization, the department must check with
the Global Ethics and Compliance office todetermine if you will be doing business in acountry or with an individual or organization thatis the subject of any applicable economic
sanctions.

13Bribery and Corruption
Rule to Remember >> Workforce members should never allow acts of bribery or corruption to influence business decisions made on behalf of RGA.

Our PolicyYour Role

What You Should Know

• RGA prohibits any business decision, with

• You must not influence or attempt to control
others to act improperly by giving or trying toprovide them with anything of value, or byreceiving anything of value to gain a competitive
business advantage.

What is a “kickback”?

• You must avoid giving or receiving
anything of value that could create theappearance of impropriety.

What is “Anything of Value”?

customers, vendors, government officials, orother third parties, that are influenced by bribery
or corruption.

• A bribe occurs when someone gives orpromises another person anything of value toobtain favorable treatment in return.

• Corruption refers to obtaining or attempting

to receive a personal benefit or businessadvantage through improper or illegal means.

• RGA is committed to conducting businessethically and in compliance with all applicablelaws and regulations, including the U.S. Foreign
Corrupt Practices Act (FCPA), the U.K. Bribery
Act, and similar laws that prohibit improper
payments from gaining a business advantage.

• Engaging in acts of bribery and corruption

not only violates this Code of Conduct andRGA policy, but may also expose RGA or
yourself to substantial fines, reputational
damage, criminal prosecution, andimprisonment.

Code of Conduct• Be aware of corruption risks inherent ininteractions with government officials – ask yourdirect supervisor or Global Ethics and Complianceto provide insight into such a situation.
• You must abide by all applicable laws thatprohibit bribery of business partners or
government officials in the countries where RGA
operates.
• Understand the role you play in anti-bribery
and corruption compliance. If you become awareof any potential or actual arrangement oragreement that may involve bribery or corruption,
immediately report the situation to Global Ethics
and Compliance or the Speak-Up Hotline.

• A kickback is a form of corruption that involves
two parties agreeing that a portion of sales or
profits will be improperly given in exchange formaking a business deal.
• This phrase means anything that might havevalue, including cash, business opportunities,
offers of employment, and more.
• There is no monetary threshold; any amount could
be seen as a bribe.
Who is considered a “Government Official”?
• Employees of any government or governmentcontrolled entity, including governmentcontrolled health care providers• Political party members, political office candidates,or political party officials• Employees of public international organizations(e.g., United Nations)• It is your responsibility to understand whether
someone is a government official. When in
doubt, consult Global Ethics and Compliance for
guidance.

14

Anti-Fraud
Rule to Remember >> Workforce members have a responsibility to report suspected incidents of fraud and to conduct their work in such a way as
to prevent fraud from occurring in the workplace.

Our PolicyYour Role

What You Should Know

• RGA is committed to conducting business• Understand the various types of fraud

Examples of common fraud scenarios andpotential indicators may include:with honesty and transparency. RGA has
established the appropriate controls for fraud
prevention, detection, and reporting.

• Fraud is defined as a knowing

misrepresentation or concealment of amaterial fact, a willful or deliberate act - or
failure to act - with the intention of obtaining
financial or other benefits to avoid an obligation.

• All workforce members are expected tounderstand the signs of potential fraudulent
activity and to promptly report any concerns.

• Engaging in acts of fraud violates this Codeof Conduct and RGA policy and exposes
RGA or yourself to potential financial losses,
administrative or regulatory actions, operationalrisks, and reputational harm.

schemes and the indicators that may signal
fraudulent behaviors.

• Be alert to signs of fraud and promptly reportany suspicious activity.

• Potential cases of fraud should be reported

to your manager, a direct supervisor, to Global
Ethics & Compliance, or through the Speak-Up
Hotline.

• You must abide by all applicable laws, rules,

and regulations related to anti-fraud in the
countries where RGA operates.

• Financial Statement Fraud: Financial

statement data is intentionally misstated oromitted.

• Asset Fraud: The Company’s assets are usedwithout permission for personal gain.

• Procurement Fraud: Payments are made to a

vendor or supplier for goods or services that do
not exist, overpriced, or unnecessary.

• Expense Fraud: Additional compensation isreceived by submitting personal expenses forreimbursement, double billing or inflating
business expenses.

• Conflicts of Interest: An employee has an

undisclosed financial interest in a consulting
firm or vendor engaged by the company.

• Claims Fraud: A policyholder or beneficiary

deliberately submits falsified paperwork tosecure monetary gain through their insurance
policy.

Code of Conduct

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Gifts and Entertainment
Rule to Remember >> Workforce members must not give or receive any inappropriate gifts or entertainment.

Our Policy• RGA prohibits workforce members fromgiving or receiving gifts and entertainment that
may be deemed inappropriate or excessive fromcurrent or prospective customers, vendors,
business partners, or government officials.

• Such conduct may influence RGA-related

business decisions or give the appearanceof affecting our ability to make objective
business decisions.

• Receiving cash gifts from customers,

vendors, business partners, or government
officials is always prohibited, as it could beviewed as excessive in nature, construed as abribe or payoff, perceived as an attempt toimproperly influence fair and impartial judgment,
and/or may violate a law or regulation. Soliciting
gifts in any form or amount is always prohibited.

• Under certain conditions, workforce

members may accept gifts andentertainment if they are determined to bereasonable, customary, infrequent, and arepresented openly and transparently.

• In addition to being reasonable, gifts given toor received from commercial partners
exceeding $250 (USD) per person require preapproval from your manager. Regardless of theamount, gifts to a government official require preapproval from your manager.

Code of Conduct

Your Role

What You Should Know

• You must not accept or receive any gifts orentertainment intended to influence your oranother individual’s behavior.

.

• Avoid accepting gifts or entertainment frompeople with whom we do business – or people
who are trying to do business with us – unless it isin connection with a legitimate business purpose
and is first brought to the attention of your directsupervisor.
• Practice moderation and common sensewhen entertaining or giving gifts on behalf ofRGA.
• Acceptance of ordinary businessentertainment (e.g., lunch, dinner, or a sporting
event) from a third party may be appropriate whenreasonable and for a bona fide business purpose.
• Entertainment accepted by others must beon the same level of propriety and integrityas that required of workforce members in thecourse of business.
• As representatives of RGA, you must not doanything that would put others outside RGA in aposition where they have a conflict of interest
relative to their responsibilities to their employer.

Question: Our team is traveling to an industry
event and will meet with a potential business
partner while there. We’ve been asked to cover
their travel and lodging expenses during theevent. Is this permissible?
Answer: This is permissible only in certain
limited circumstances and requires yourmanager’s pre- approval if these expenses
exceed $250 (USD) per person for commercial
partners. RGA’s Managing Counsel must
approve travel and lodging expenses forgovernment officials or commercial partners
and all requests must be made in writing.

Question: An RGA commercial partner isseeking RGA’s help to support a charitablecause/entity. How should this be handled?
Answer: All requests must be made inwriting and submitted to Human Resources.
RGA’s Managing Counsel and Corporate
Social Responsibility office must approve all
charitable donation requests.

• Contact Global Ethics and Compliance withany questions or guidance about gifts orentertainment.

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Protection of RGA Assets
Rule to Remember >> Workforce members have a responsibility to protect RGA’s physical assets as well as the personal and sensitive data RGA
hosts on its systems.

Our PolicyYour Role

What You Should Know

• RGA prohibits the unauthorized or improper• Except as expressly authorized by RGA, you
may not use, disclose, or distribute RGA’s
information or physical assets, whether
intentionally or negligently. RGA strictly prohibits
such unauthorized acts. In some cases, such acts
could also be illegal.

Categories of RGA Assets

use of RGA property, including its intangible
property and technology assets, such as data,systems, and intellectual property. Workforce
members must respect the intellectual property ofothers.

• RGA is committed to complying withapplicable security and privacy laws in the
countries where we conduct business, including
regulations regarding the cross-border transfer of
specific categories of data.

• Any intellectual property that is createdby a workforce member within the scopeof their employment at RGA, including but
not limited to, new business methods,
brochures, and internally developed
software, belongs exclusively to RGA.

• Use of RGA’s email and internet services

should be used for legitimate businesspurposes, but incidental and occasional personaluse of email and internet is acceptable.

• RGA reserves the right to monitor or

audit any of RGA’s information or physicalassets in compliance with applicable laws andregulations.

Code of Conduct• Avoid unauthorized copying or use of any
licensed or copyrighted materials such as
computer software or computer storage media.
• You may not send, and should not receive,
any inappropriate electronic communications
over RGA communications systems.
• You are prohibited from forwarding businessrelated emails and information to your personal(e.g., Gmail or Hotmail) email addresses, as suchan action does not allow for the appropriate
protection of information, which may include
personal data or proprietary information in theemail.
• Follow the applicable security and privacy laws
and regulations of countries in which RGA
operates.
• You must report any witnessed orsuspected misuse of RGA’s physical orinformation assets.

RGA’s physical and information assets are provided to
conduct authorized business on behalf of RGA.
• Physical assets include tangible items such asreal estate, equipment and systems, officeequipment, and supplies.
• Information assets include material, non-public
information, trade secrets, patents, data,applications, databases, electronic storage
locations, trademarks, business plans, and other
innovative or creative ideas.

.

Question: I run a small sport betting pool with
my friends that I want to expand with workforce
members at RGA. Can I use my RGA email
account to distribute bracket information tocoworkers?
Answer: No, the RGA email system should not
be used to support or advance gambling. Given
the complicated laws surrounding betting atwork, allowing these emails may place RGA in
a position with unwanted consequences. Suchnon- business activity can have a negative
effect on the performance and availability of
our computer network, which is an important
RGA resource.

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Statements and Records
Rule to Remember >> Workforce members are honest and accurate in communications and recordkeeping on behalf of RGA.

Our PolicyYour Role

What You Should Know

• RGA requires that workforce members• Workforce members must never falsify,
misrepresent, or conceal records.

Examples of Social Media

create and maintain records accurately andcompletely.

• RGA must maintain strict compliance with boththe spirit and the letter of all laws andregulations governing disclosure, financial
reporting and records, and exercise responsible
use of and control over financial assets.

• Any email, voicemail, or othercommunication sent by a person having
apparent authority to speak for RGA (forinstance, an email sent over RGA’s enterpriseservers), is considered official communicationfrom RGA to an outside person or entity.

• Employees must direct all inquiries fromthe media to RGA’s Corporate
Communications department for review
before responding to the press.

• Social media containing inaccurate or

misleading statements could lead tomisunderstandings, violate commercial contracts
or confidentiality agreements, result in liability for
RGA and its staff, damage relationships, or breakthe law.

Code of Conduct• Always comply with record requests byregulatory authorities or RGA auditors.
• Do not act or speak for RGA except strictly
within the boundaries of your authority.
• Be knowledgeable before posting onsocial media. Follow all RGA policies,
applicable laws, including copyright, dataprotection, libel, and slander.
• You must receive approval from Corporate
Communications before posting on behalf of
RGA for company purposes.
• Do not divulge or discuss confidential
information about RGA or share information
about your colleagues on any form of social
media.
• You alone are responsible for what you poston social media. State that any opinions you
express, especially about RGA, are your own
and do not reflect those of RGA. Respect
yourself and your peers.

• Social networking sites (Facebook, Twitter)• Professional networking sites (LinkedIn)• Video and photo-sharing sites(Instagram, Snapchat, TikTok)• Blogs and microblogging sites (Tumblr)• Online forum and discussion boards (Reddit)• Streaming services (YouTube)• Question-and-answer forums (Yahoo! Answers).

Question: I ordered some software and mysupervisor is asking me to record the charge
against another expense category because ourbudget for software has been exceeded. Whatshould I do?
Answer: Remind your supervisor that no one
should knowingly make an incorrect recordin the books and records of RGA. If yoursupervisor persists, contact another leader, theGlobal Ethics and Compliance office, or the
Speak-Up hotline.

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For questions or more information,please contact Global Ethics &Compliance at compliance@rgare.com.

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