FINANCIAL MANAGEMENTCODE OF PROFESSIONAL CONDUCTREINSURANCE GROUP OF AMERICA, INCORPORATEDThis Code of Professional Conduct (“Code”) applies to the Chief Executive Officer, the Chief FinancialOfficer, the Corporate Controller, and all officers (Vice President and above) in a finance, accounting,treasury, tax, actuarial (within the Finance and Valuation departments), audit or investor relations role.
These professionals are expected to adhere to this Code, take personal responsibility for conducting thebusiness endeavors of RGA fairly, promote a culture of honesty and accountability, and act and advocatethat others act in conformity with the core values of RGA and this Code. These professionals are also
expected to adhere to the RGA Code of Conduct as well as all other applicable RGA policies andguidelines.
Every employee involved in financial management in the RGA enterprise shall:•Act honestly and ethically, avoid or resolve actual or apparent conflicts of interest in personaland professional relationships, and promptly disclose any material transaction or relationshipthat reasonably could be expected to give rise to such a conflict of interest to the General Counsel
or as provided in the RGA Code of Conduct.

•Promote and provide appropriate disclosures to stakeholders that present fairly the information
therein (e.g., accurately, completely, objectively, relevantly, timely and understandably), in
accordance with applicable laws, rules and regulations.

•Comply with applicable laws, rules and regulations of federal, state, foreign and local
governments, and private and public regulatory agencies.

•Adhere to, and, where applicable, monitor and improve, RGA's processes to maintain effective
internal control over financial reporting.

•Act in good faith, responsibly, with due care, competence and diligence, using considered,professional, independent judgment, and seek at all times to present all reasonably available
material information on a timely basis to management and others in accordance with RGApolicies.

•Protect the confidentiality of information acquired in the course of his or her work.

•Use confidential information acquired in the course of his or her work only for proper RGA
business purposes, and not for personal advantage.

•

Proactively promote and be an example of ethical behavior as a responsible partner among peers
and other associates in the work environment.

•Promptly report violations of this Code using the procedures for reporting violations as describedin the RGA Code of Conduct and Speak Up Policy.

Administration
In the event of any uncertainty as to whether an Associate is subject to this Code, the Chief Financial
Officer shall make a determination of its applicability and inform the appropriate individuals or business
units.
Investigation and violations of this Code will be handled in the same manner described in the RGA Codeof Conduct. Violators of this Code and those who supervise or manage them shall be subject to disciplinaryaction. Managers who retaliate against an employee reporting a violation shall also be subject todisciplinary action.
Disciplinary action may include, but is not limited to, reprimands and warnings, probation, suspension,demotion, reassignment, reduction in compensation or immediate termination. Certain actions andomissions prohibited by the Code might also be unlawful and could lead to criminal prosecution,
imposition of fines or imprisonment.
Only the Board of Directors or the Audit Committee may waive provisions of this Code for the Chief
Executive Officer, the Chief Financial Officer or the Corporate Controller and any such waiver shall bepromptly disclosed in accordance with applicable laws, rules and regulations.

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