Supplier Code of Conduct
November 2022

AIG SUPPLIER CODE OF CONDUCT

2CONTENTS

A MESSAGE FROM OUR CHIEF
PROCUREMENT OFFICERA MESSAGE FROM OUR CHIEF
PROCUREMENT OFFICER

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1. ETHICS AND STANDARDS
OF CONDUCT 

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2. LEGAL AND REGULATORYCOMPLIANCE5
3. LABOR AND HUMAN RIGHTS 

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4. CITIZENSHIP 

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5. PROTECTION OFAIG INFORMATION

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6. COMPLIANCE MANAGEMENT 10
7. VIOLATION OF THIS POLICY 

American International Group, Inc., along with its subsidiaries and affiliates(collectively “AIG”), is committed to conducting its business in accordance withthe highest ethical and social standards and in full compliance with all applicablelaws and regulations in the United States and in other jurisdictions in which AIG
operates or does business. We recognize that our suppliers (“Suppliers”) play animportant role in our success. Accordingly, AIG strives to conduct business with
Suppliers who share our commitment to high ethical standards and who operate ina socially responsible manner. This Supplier Code of Conduct presents principles
and minimum standards for Suppliers to follow in their dealings with AIG. Our
Suppliers should also apply these or similar principles to the suppliers with whomthey work in providing goods and services to AIG. This Supplier Code of Conduct is
not exhaustive, and the contract(s) entered into between AIG and a Supplier include
additional policies and standards. When a contract between a Supplier and AIG
contains more restrictive provisions than those in this Supplier Code of Conduct,
the terms of the contract govern.
Sincerely,

11

Jeanne Edwards
AIG Global Chief Procurement Officer

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1. ETHICS AND STANDARDS OF CONDUCTAIG Property, Funds and Information
Suppliers must handle all AIG property, including, but not limited to equipment,
funds, documents, information (in any format, including electronic and hardcopy), and communications systems, with care and according to AIG requirements
and instructions. Suppliers must promptly report to AIG any suspected or actual
unauthorized access to or acquisition of, misuse, theft, vulnerability, improper
exploitation, loss or sabotage of AIG property of which they become aware.
Records
Records prepared for AIG or maintained on behalf of AIG by Suppliers, including
records of work time, expenses, and AIG business records, must be accurate,complete and retained in accordance with applicable legal and regulatory record­
keeping requirements or otherwise as specified in a relevant contract between the
Supplier and AIG.
Conflicts of Interest
Suppliers must avoid engaging in any activity that would create an actual or
potential conflict of interest regarding their provision of products or services to AIG. A
conflict of interest exists where an AIG employee, or an employee’s immediate family
member, has a financial or personal relationship with a Supplier or its personnel, andthis relationship could interfere with or influence the way AIG engages the Supplieror conducts or oversees the work done by the Supplier for AIG. Suppliers must notknowingly deal directly with an AIG employee who has or whose family memberor relative, including a spouse or domestic partner, has a financial interest in the
Supplier. In the event an actual or potential conflict of interest arises in connection
with AIG, Suppliers must immediately report it to AIG – see Section 7 (Violation ofthis Policy, How to Report).
Alcohol and Drugs
Suppliers must not engage in any work for or on behalf of AIG, or in any fashion
represent AIG, while under the influence of alcohol or other substances that may
impair the Suppliers’ judgment or ability to work safely. In addition, Suppliers may
not use, possess, or work under the influence of, drugs or controlled substances
while on AIG premises or while conducting business with or for AIG.
Business Courtesies
Suppliers must not provide entertainment that could harm AIG’s reputation.
Suppliers must never provide gifts or entertainment intended to improperly influence
any person’s business judgment or that might create the appearance of undue
influence. AIG expects that, in dealing with AIG employees, Suppliers will not offer
a gift or anything of value which exceeds US $150. In some circumstances, local
law or AIG policies may require a lower limit on gifts or prohibit them entirely. It
is never permissible for Suppliers to give cash or cash equivalents (e.g., gift cards)
as a gift to an AIG employee, regardless of the amount. When Suppliers work with
AIG in providing goods and services to government entities, or otherwise deal
with governmental officials or employees of government-owned or governmentcontrolled enterprises in connection with AIG matters, gifts or entertainment of any
value are not permitted without AIG’s express prior written authorization.

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2. LEGAL AND REGULATORY COMPLIANCE
Generally
Suppliers must conduct their business in compliance with all applicable laws, rules,
and regulations of the jurisdictions in which they operate.
Business Integrity
Suppliers are prohibited from engaging in any form of illegal or inappropriate activity,
including, but not limited to, corruption, misrepresentation, extortion, embezzlement
or bribery.
Economic Sanctions, Anti-Boycott and Export Controls
Suppliers shall not perform their obligations in any way that would cause AIG to be in
violation of U.S. or international trade restrictions applicable to the Supplier or AIG.
Accordingly, Suppliers must:comply with all U.S. and all applicable international economic sanctions laws andregulations, as well as all applicable U.S. and international export controls applicableto the Supplier or AIG; not conduct business with individuals, entities, organizations,or countries that are the targets of U.S. or applicable international economic
sanctions laws and regulations; and never participate in any boycott or restrictive
trade practice in violation of U.S. anti-boycott laws. Prohibited boycotts include theArab League boycott of Israel.
Antitrust and Competition Law
Suppliers must comply with all applicable U.S. and international antitrust andcompetition laws and regulations and compete lawfully in all markets in which
they operate. Suppliers must obtain sensitive data about AIG competitors only
from lawful and appropriate sources and in a lawful and appropriate manner,and never discuss with any AIG competitor AIG’s prices, bids, customer sales,or other competitively sensitive information.

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Anti-Money Laundering
Suppliers must comply with all applicable U.S. and international laws andregulations pertaining to the detection, prevention, and reporting of potential
money laundering and terrorist financing activities.
Anti-Corruption
Suppliers must comply with all applicable U.S. and international anti-corruption
laws, including the United States Foreign Corrupt Practices Act, and all otherapplicable laws that prohibit corruption, extortion, kickbacks, or bribery (or thatprohibit the failure to prevent these acts). Suppliers must:never pay or receive bribes or provide other improper benefits to any person to
obtain or retain business or secure a business advantage, promise or offer;
must never authorize the payment of money or anything else of value to agovernment official, including employees of government-owned or government­
controlled entities, in order to obtain or retain business or secure a businessadvantage; and must maintain books and records that accurately reflect the true
nature of transactions.
Insider Trading
Suppliers must never transact in AIG securities, including common stock, debt
securities, or any other type of securities that AIG may issue, while in possession ofmaterial, non-public information relating to AIG. Suppliers must also never transact
in another company’s securities (including companies unaffiliated with AIG) if they
are in possession of material, non-public information regarding such company
obtained in the course of performing services for AIG. Suppliers must never passon (or “tip”) confidential or material non-public information about AIG or any othercompany to others or recommend to anyone the purchase or sale of securities of
AIG or any other company if they are in receipt of material non-public information
learned in the course of an engagement with AIG.

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3. LABOR AND HUMAN RIGHTS
Non-Discrimination
Suppliers must not engage in discrimination on any basis prohibited by applicablelaw, including, without limitation, race, color, religion, age, gender, sexual orientation,
gender identity and expression, national origin, disability, family or marital status,
citizenship status, veteran status or military status. AIG embraces diversity and equal
opportunity as fundamental principles and key components of its corporate strategy.
We strongly encourage that all Suppliers do the same. Suppliers must also maintaina workplace culture based on respect where all unlawful harassment and abuse,including sexual harassment, is forbidden. Disciplinary policies and procedures mustmeet legal mandates as applicable and be clearly defined and communicated toSuppliers’ employees. Suppliers’ employees shall have completed all legally required
training, including, without limitation, training related to the prevention of sexual
harassment.
Zero Tolerance for Harassment and Intimidation
Suppliers must not engage in intimidating or bullying behavior, which can occur asa single instance or repeated inappropriate behavior. Bullying or intimidation can bedirect or indirect, intentional or unintentional, conducted by one or more persons
against another or others, at the place of work, or in the course of employment.
Bullying or intimidation can manifest itself verbally, non-verbally, online, physically,in gestures, and in exclusionary behavior.
Working Hours and Wages
Compensation paid to workers by Suppliers must comply with all applicable local
wage laws, including those relating to minimum wages, overtime hours and legally
mandated benefits. Suppliers’ employees must have the ability to earn fair and equal
wages, as determined by applicable local law. Suppliers must take steps to ensure thatno form of modern slavery exists in their supply chains or business organizations.
Suppliers are fully responsible for the quality, performance, behavior, supervision andprotection of their personnel. AIG retains the right in its absolute discretion to require
the removal of any individual from an AIG job site for any reason.
Worker Protection
Suppliers shall take appropriate measures to prevent workplace injuries andillnesses, to provide their personnel with a safe and healthy working environment,
and to ensure the health, safety and welfare of their personnel and others who may
be affected by their business activities.
Suppliers shall at all times handle information about its own employees as well as
any information about individuals that it obtains in the course of its dealings with
AIG appropriately and only when necessary for business purposes and in a mannerthat protects against harm such as discrimination, stigmatization or other damage to
reputation and personal dignity, impact on physical integrity, fraud, financial loss or
identity theft.

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4. CITIZENSHIP
Generally
AIG is committed to making a positive difference in the communities where we work,
live and serve our customers, and AIG expects the same of Suppliers. AIG strives
to conduct business with Suppliers who share our commitment to high ethicalstandards and who operate in a socially responsible manner.
Compliance with Environmental Laws
Suppliers must comply with all applicable environmental laws and requirements,
including those relating to: the management and disposal of waste; monitoring andreporting of air and water emissions; management of chemical storage and use; andprocurement of required licenses, permits, reports, and payments of fees.
Sustainability
AIG strives to be an advocate in sustainability initiatives within its organization andto support a sustainable supply chain to meet its core objectives. Suppliers muststrive to improve their organizational processes by establishing and implementing
sustainability goals in support of minimizing environmental impact, and by
managing social risks ethically and responsibly.
To the extent reasonably practicable, Suppliers must take actions to reduce waste,emissions, and energy use associated with their operations.
Diversity
In support of AIG’s commitment to diversity, Suppliers are encouraged to review
AIG’s Supplier Diversity program information here.

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5. PROTECTION OF AIG INFORMATION
Confidential Information
Suppliers must keep confidential all AIG proprietary and non-public information,
including non-public personal information received from, processed on behalf of,or disclosed by AIG. Suppliers must take precautions to safeguard this information,
including ensuring that Suppliers’ personnel are under appropriate confidentiality
obligations and adequately trained to safeguard confidential information.
Data Privacy and Security
Suppliers must comply with all applicable data privacy and security laws andregulations, including laws and regulations regarding the cross-border transfer of
personal information. Suppliers must maintain appropriate procedures, safeguards,
and controls to secure and protect the confidentiality integrity and availability ofconfidential information, including personal information, received from, processedon behalf of, or disclosed by AIG or third parties on AIG’s behalf. Suppliers must
promptly notify AIG of any suspected or actual compromise or risk of compromise
to the confidentiality, integrity or availability of such confidential information. In
addition, Suppliers must promptly notify AIG of any complaints or requests received
from individuals relating to personal information received from, processed on behalfof, or disclosed by AIG, in accordance with applicable privacy laws and regulations.
Notification can be made in accordance with the notification mechanism specified
in the relevant contract between the Supplier and AIG or pursuant to Section 7(Violation of this Policy, How to Report).
Intellectual Property, Including Use of AIG’s Name and Brand Trademarks
Suppliers must not infringe, misappropriate or misuse intellectual property of AIG,
AIG’s business partners, or AIG’s other Suppliers. Suppliers must obtain the express
written consent of AIG or the applicable owner before using or disclosing AIG’s oranother party’s intellectual property to third parties.
Suppliers permitted in writing to use AIG’s name and/or Brand Trademarks must
adhere to applicable brand guidelines for using AIG’s name and/or Brand
Trademarks to help deliver a unified, consistent and quality AIG brand experience,protecting and upholding AIG’s reputation.
Competition, Advertising, Marketing and External Communications
AIG expects Suppliers to uphold fair business standards in advertising, sales andcompetition. Suppliers may not reference their relationship with AIG, such as
through the use of AIG’s name, logo, trademarks, or services in any vendor
marketing, promotional items, social media or other communications of any
kind, whether written or verbal, without AIG’s prior written approval. AIG approved
advertising materials must be truthful and accurate, with clear and conspicuous
disclosure of material terms and limitation of advertised offers.
Suppliers must not make any public statement concerning AIG, its affiliates,
partners, suppliers and advisors, and any media inquiries received by Supplier
about any of these matters should be referred to AIG immediately.

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6. COMPLIANCE MANAGEMENT
Training and Competence
AIG expects that Suppliers will maintain a training program adequate to ensurethat management and employees comply with all regulatory requirements andexpectations set forth in Supplier’s contracts with AIG and this Supplier Code​of Conduct.
Business Continuity, Disaster Recovery, and Incident Management
Suppliers are responsible for the development, implementation, and testing ofappropriate business continuity plans and disaster recovery plans for operations
supporting AIG business to validate effectiveness. This also includes theimplementation of incident management plans that address how any disruption ​orpotential disruption is managed and communicated with AIG.
Supply Chain Management
Suppliers must take all reasonable steps to ensure that their sub-suppliers are incompliance with applicable laws and regulations as well as applicable requirements
in Supplier’s contracts with AIG and this Supplier Code of Conduct.
Procurement Transparency
AIG Global Sourcing & Procurement Services is the sole authorized organization forthe conduct of procurement business on AIG’s behalf. Accordingly, Suppliers must
promptly inform their AIG Global Sourcing & Procurement Services contact wheneverthey are engaged by AIG to provide a quote, order form, statement of work, contract,
or any other form of proposal for new business. If a Supplier does not know who
their AIG Global Sourcing & Procurement Services contact is, they should email
SupplierRelationshipManagement@aig.com.

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7. VIOLATION OF THIS POLICY
How to Report
Suppliers must promptly report concerns and suspected or actual violations of thisSupplier Code of Conduct. Suppliers should contact their AIG Global Sourcing &Procurement Services contact directly (see Section 6 above) or they may contact anyof the following:
AIG’s Global Compliance Group at +1 646-857-1877, or email at
corporatelegalcompliance@aig.com.
The AIG Compliance Help Line at +1-877-244-2210 or online at ​www.aigcompliancehelpline.com, or by using your mobile camera device byscanning the QR code below.

Communications to the Help Line may be made anonymously, subject to local laws,
and may be made in all major languages.
Assistance with Investigations
Suppliers must provide reasonable assistance to any investigation by AIG of the
Supplier’s suspected or actual violation of this Supplier Code of Conduct. Suppliersmust protect anyone who works for them, either as an employee or a contractor,
from any form of retaliation for reporting suspected or actual violations.
Review by AIG
AIG reserves the right to review or audit Supplier’s compliance with this Supplier
Code of Conduct. Suppliers are to promptly respond to requests for informationfrom AIG, or a third party working on AIG’s behalf, regarding matters covered by thisSupplier Code of Conduct. These may include surveys, questionnaires, requests forsupporting documentation and other measures intended to increase visibility into
AIG’s Supplier relationships.
Consequences of Non-Compliance
AIG will incorporate ongoing Supplier Code of Conduct compliance into its
evaluation of business relationships and into its procurement decisions. Violationsof this Supplier Code of Conduct may affect Supplier’s standing with AIG, may leadto disqualification from future opportunities with AIG, and may even result in thetermination of the Supplier’s business relationship with AIG.

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