VIG CODE OF BUSINESS ETHICS

We ensure that we know and comply with all legal requirements that affect our business activities. In all aspects of the COBE and across all our countries, we admit to act in compliance with the legal and regulatory provisions. Moreover, we comply with obligations which have been adopted on a voluntary basis, with internal standards as well as commonly accepted ethical standards and international agreements. In our business environment, we refuse to getting involved in any illegal practices and do not approve any illegal actions which may lead to the involvement of VIG in unlawful behaviour. Moreover, we avoid any involvement in activities whose evident intention is to evade any legal or voluntary provisions or standards.

We respect and support the protection of international human rights in our business practice. We strive to engage only in business that is in line with human rights standards. Our behaviour is guided by related international conventions, especially the UN Global Compact, the UN Sustainable Development Goals, and the International Bill of Human Rights.

We see diversity as a reflection of the similarities and differences that we encounter at VIG, in our markets, at the local Group companies, as well as in our partners, customers and employees. At VIG, diversity management involves genuine respect for, an open-minded approach to and conscious efforts to capitalize on our diversity.

We respect the cultures and traditions of the various countries and markets in which we offer our products and services.

We do not tolerate any kind of discrimination. We are committed to promoting equal opportunities with regard to the employment and promotion of staff, regardless of their faith, religion, sex, beliefs, ethnicity, nationality, sexual orientation, age, skin colour, disability or civil status.

We do not condone sexual harassment or bullying and always strive to treat each other in an appreciative and positive manner.

We are aware that we all have a role to play in protecting the environment. Hence, we use resources carefully and consider the implications for the environment in our actions and decisions.

We are committed to maintaining a healthy and safe working environment and fair working conditions. Behaviour that threatens the health or safety of others or ourselves shall be avoided at any time.

Generally, company property and resources shall only be used for professional purposes unless otherwise provided by internal rules, and in accordance with internal regulations. We are committed to treating company property, such as operational equipment, operational facilities as well as intangible goods (e.g., intellectual property including software licenses) with care and to protect them against abuse, loss or theft.

We ensure that our private interests do not conflict with our obligations with respect to VIG. A conflict of interest is a situation where our personal interests (circumstances and/or relationships) or interests which result from assuming (multiple) functions in the same or another Group company or in an external company, may be opposite to the interests of the Group company, which we shall preserve when exercising our function, in a way that the obligation to exercise our function in a reliable, honest, fair and objective manner may be compromised. Conflicts of interest may, for instance, occur when we or persons close to us receive undue advantage from our position within VIG or from the disclosure or access to confidential information. In any case, we comply with any applicable legal and regulatory provisions regarding conflicts of interest.

Conflicts of interest shall be identified as early as possible and generally be avoided. If a conflict cannot be avoided, we handle it in a fair and professional way; this especially includes the immediate disclosure of the conflict to our superior.

As conflicts of interest may arise from secondary employment (e.g., political offices, services, lecturing or consulting activities, functions in legal entities, honorary activities), we may only take on such employment if and insofar as any conflict of interest, including any appearance thereof, can be excluded. Secondary employments with competitors of our VIG employer are in general strictly prohibited.

We oppose all forms of corruption and bribery. Corruption is the misuse of authority for the private gain of individuals, whether through active or passive conduct, as a recipient or a provider.

• Gifts, Invitations and other Benefits
  We are not allowed to accept gifts, invitations or any other benefits nor to make any gifts, invitations or grant any other benefits whose value exceeds the applicable legal provisions or the local standards and/or which are made with the intention of gaining an improper advantage. We treat gifts, invitations or benefits to public officials with particular care.
• Donations and Sponsorship
  We are committed to making donations and sponsorship payments only within the legal frameworks and to the extent that these contributions do not damage the reputation of VIG.
• Political Contributions
  We refrain from making any contributions including donations and sponsorship payments to political parties and related organisations.

We diligently observe EU and local data protection regulations. We protect personal data provided by clients, business partners and employees from unauthorized access or unlawful use and against accidental loss, destruction or damage. Personal data is collected, processed and used only for specified, explicit and legitimate purposes, and to the extent they are strictly necessary. We respect the comprehensive rights of the persons whose data we collect, process or use.

Confidential information held by us or which has been made available to us by clients or business partners is subject to our confidential treatment and to our obligation to maintain secrecy thereon. We disclose confidential information only on a need-to-know basis or if specifically authorized or legally required.

As a market participant, we respect our competitors and the concept of free market and thus fully comply with all applicable antitrust rules. We reject conduct that is likely to discredit competitors, their products or services, or mislead customers in their assessment of competitors. Furthermore, we do not tolerate any form of conduct aiming at restricting free and fair competition, and refrain from any conduct that adversely affects the market.

We take action to prevent market abuse, i.e. the abuse of insider information and market manipulation.

In case we possess inside information, we are prohibited from directly or indirectly dealing with the respective financial instruments for our own account or the account of a third party by using the inside information or from making recommendation to others regarding the financial instruments concerned ("insider dealing"). Additionally, we will not unlawfully disclose or make otherwise available inside information to third parties. We do not disseminate information or take any action, which gives or is likely to give false or misleading signals as to the supply of, demand for, or price of a financial instrument.

We support international efforts to prevent the abuse of financial systems for money laundering purposes and the financing of terrorist activities. In order to aid the prevention of and to participate in the tracing of such abuse, we are committed to obtaining reliable information about the identity of our clients in terms of the ‘know your customer’ principle in all countries which we operate in. We pledge to carefully check and, if necessary, to reject any business that appears to be unlawful.

We respect all applicable international and national sanctions and refrain from engaging in any business activities subject to such sanctions as well as from entering into business relationships with or providing financial services to sanctioned persons and organisations.

We deal with business cases and concerns of customers and business partners always in a correct, competent, friendly, professional and timely manner, and do not condone any deceptive or misleading practices. We strive to give our customers the best possible advice and provide them with all relevant information to enable them to come to a well-informed and appropriate decision in their best interests. We ensure that complaints of customers or business partners are dealt with fairly and in a timely manner in accordance with all applicable legal provisions.

Our relationships with business partners and authorities distinguish themselves through mutual, honest, fair, respectful and reliable collaboration. We are open to communication and cooperation both at national and international level. Communication with the media, shareholders and public authorities is to be handled by authorized persons and functions only (e.g., Management Board, spokesperson).

If we appear in public or take part in public discussions in a manner that might be perceived to be acting as a representative of VIG without having had the authorisation to do so, we shall make clear that we act as private persons.

We are committed to providing complete, accurate, fair, truthful, understandable and timely financial information. We guarantee compliance with both local and group accounting standards and fulfill our tax obligations. In addition, we work closely together with financial market regulators and other regulators to ensure the integrity of information.