Speak-Up Policy
May 2022

Speak-Up Policy

PurposeThe objective of the Speak-Up Policy is to provide a consistent mechanism for reporting and investigatingsuspected violations of law, rule, regulation, internal policy, or the Code of Conduct across Reinsurance Group ofAmerica, Incorporated and all of its subsidiaries and affiliates (“RGA”). The Speak-Up Policy aims to:▪ Ensure all Workforce Members and other persons dealing with RGA feel supported in speaking up andreporting matters they suspect may involve improper, unethical, or inappropriate conduct;▪ Encourage all improper, unethical, or inappropriate behavior to be identified and challenged at all levels of theRGA organization; and▪ Reinforce RGA’s Non-Retaliation Policy through the assurance that all reports will be taken seriously, treatedas confidential to the extent permitted by law, and managed without fear of retaliation.

Scope
The Speak-Up Policy applies globally to all Workforce Members throughout RGA. “Workforce Members” include
any regular or temporary employee, contingent worker, contractor, consultant, or individuals representing oracting on behalf of RGA. The policy also extends to any party of a current or prior relationship with RGA(including, but not limited to, former Workforce Members, family members of Workforce Members, shareholders,vendors, and customers) who wish to raise a concern about possible misconduct within RGA.

What to Know
Each Workforce Member has a duty and obligation to speak up
upon learning of potential misconduct. RGA encourages you toreach out to your direct supervisor as your first point of contact
as they are often in the best position to understand your specificconcern and take the appropriate action. In some jurisdictions,(e.g., the United Kingdom), a protected disclosure can also bemade to local regulators.
If you are not comfortable reporting a potential violation to yourdirect supervisor or another leader, RGA offers the Speak-Up
hotline as an option.

How to Speak Up:•In Person by speaking with your directsupervisor, another leader, Global
Human Resources, Global Ethics andCompliance, or Global Legal Services•By Phone or Online by visiting theSpeak-Up hotline website forinformation on both options

Managed by a third-party reporting service, the Speak-Up hotline is a comprehensive reporting tool to assist
management and employees in addressing fraud, policy violations, and other misconduct in the workplace, all while
cultivating a positive work environment at RGA.
▪ Confidentiality Any information you provide to the Speak-Up hotline will be treated as confidential to theextent allowed by local law and regulation. All workplace concerns are handled with discretion andsensitivity. Therefore, if you participate in or learn about an investigation, you must keep the matter
confidential.
▪ Anonymity Where allowed by local law, you may choose to remain anonymous when speaking up. If you
request anonymity, we will not reveal your identity and will take all reasonable steps in any investigation toreduce the risk of you being identified. However, if possible, we encourage you to reveal your identity as insome circumstances, it can be challenging to investigate reports that are made anonymously.
▪ No Liability You shall not be subject to any civil, criminal, or administrative liability (including disciplinaryaction) and no contract right will be exercised against you for speaking up about a concern or potentialviolation.
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Speak-Up Policy▪ Investigations Any investigations shall be conducted in a fair and unbiased manner concerning all parties
involved. Details of the case, your identity, and the identity of anyone else mentioned in the report, are only
shared on a need-to-know basis in accordance with all relevant and applicable laws. You should neverwithhold, tamper with, or fail to communicate relevant information in connection with an investigation.
▪ Non-Retaliation Speaking up is encouraged, and individuals who speak up are protected. You should feel
confident that you will not suffer as a result of raising concerns in good faith about suspected misconduct. No
form of threat or retaliation will be tolerated. Retaliation is treated as a disciplinary matter. You will not beprotected, however, if you maliciously raise a concern that you know is false. For more information about
RGA’s position on non-retaliation, please refer to the Non-Retaliation Policy available on the Policy Portal.

What to Do
We all must speak up if we witness or suspect a violation of law, rule, regulation, RGA policy, or the Code ofConduct. By speaking up, you provide RGA the opportunity to deal with the issue appropriately.
If you believe you are being asked to act illegally or improperly, you are required to speak up. Remaining silent
about possible misconduct may allow a situation to worsen and may lead to an increased risk of financial andreputational loss to RGA caused by the misconduct.
Examples of potential violations or concerns which should be reported include, but are not limited, to thefollowing:▪ Discrimination or harassment▪ Disclosure of confidential information▪ Misstatement of financial or non-financial
Records▪ Violation of applicable laws, rules, orregulations▪ Bribery, corruption, or kickbacks▪ Violations of RGA policies or Code of Conduct▪ Conflicts of interest▪ Improper use of RGA’s information assets▪ Insider trading▪ Environmental, health, and safety Issues

Disclaimer: Due to local privacy and whistleblower laws in individual countries, your Speak-Up hotline may be
programmed to only permit specific types of reports such as accounting, financial, audit, and bribery matters. Inthese countries, you may contact a member of Human Resources or Global Ethics and Compliance to reportother types of issues.
Workforce Members should act in good faith by providing all of the information they have and believe to be true. If
you become involved in an investigation, you must answer all questions thoroughly and honestly.

What to Avoid Reporting▪ Immediate Threats to Life or Property If emergency assistance is needed, please contact your local
authorities or call your country’s emergency phone number.
▪ Wage and Salary Issues File any employment grievances about your wage or salary with the proper
Human Resources contact.
▪ False Reports Workforce Members must report concerns honestly and in good faith. False accusations
and lies are a policy violation and may lead to disciplinary action, leading up to and including termination.
▪ Attempted Exemption by Self-Reporting Workforce Members cannot exempt themselves from theconsequences of misconduct by self-reporting.

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Speak-Up PolicyQuestions and Concerns
For specific guidance on speaking up, please contact the groups or individuals identified below:

TopicGroup/Individuals

Contact Information

Report concerns or potential
violations

RGA Speak-Up hotline

RGA Speak-Up Website

Global Ethics and Compliance(GEC)compliance@rgare.com

Laws, regulations, internal policies,
treaties, and other contractual
obligations
Human Resource related questions
and concerns

RGA Legal Counsel

Human Resources Department

Human Resources Representative

AppendixDefinitions of Terms
Bribery Giving money or some other valuable item to improperly influence a public official (i.e., any
governmental employee) or commercial partner in the performance of their duties to obtain or retain a businessadvantage.
Conflict of Interest Any act or circumstance that could, or could appear to, cast doubt on a Workforce Member’sability to act with total objectivity in conducting RGA business.
Corruption Wrongdoing on the part of an authority or powerful party through means that are illegitimate orincompatible with ethical standards and is associated with bribery.
Discrimination Unequal treatment of individuals for reasons that have nothing to do with ability. Federal andstate laws prohibit discrimination in employment, rates of pay, right to promotion, etc. based on race, nationality,creed, color, age, sex, or sexual orientation.
Harassment Any words or actions that create an intimidating, hostile, or offensive work environment.
Insider Trading Use of confidential, non-public information about a business gained through employment in acompany to buy and sell stocks and bonds based on the private knowledge that the value will go up or down in
the future.
Kickback A form of corruption that involves two parties agreeing that a portion of sales or proﬁts will be
improperly given in exchange for making a business deal.
Workforce Member Any regular or temporary employee, contingent worker, contractor, consultant, or individuals
representing or acting on behalf of RGA.

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Policy Information
Document Information
Current Version Number

5.0

Policy Owner

Casey Beckman, VP, Global Compliance & Fraud

Policy Manager

Beth Dean, Compliance Lead

Effective Date

May 2022

Version Notes

Date of VersionApproval

Version Number

Version Author(s)5.0Beth Dean

Reviewed during the two-year review cycle; minor
grammatical changes applied.

May 2022

4.0

Beth Dean

Reviewed during the two-year review cycle; minorchanges applied.

June 2020

3.0

Lee Emmenderfer

Minor updates made to the policy to comply with
Australia’s Treasury Laws Amendment (Enhancing
Whistleblower Protections) Bill 2018.

June 2019

2.0

Lee Emmenderfer

Inclusion of text informing reader of option forreporting to local regulators in certain jurisdictions.

January 2019

1.0

Lee Emmenderfer

Initial Draft of Speak-Up Policy

June 2018

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