Zurich Insurance : Code of Conduct English

We care

Our Group's Code of

Foreword

"Dear colleagues,

As an insurer, we have a crucial responsibility to our customers and society. By behaving ethically and responsibly and by standing up for what is right, we demonstrate to our customers, each other and all our stakeholders that we care about them and that we are worthy of their trust, something that is vital for our long-term success.

Our industry is undergoing a fundamental transformation. In this evolving landscape, Zurich must remain agile to position itself for continued success in order to exceed our customers' and other stakeholders' expectations. While our business is changing, our commitment to ethical behavior remains steadfast.

We are committed to fostering a culture of ownership and accountability at Zurich. Together, we are responsible for embodying our Code of Conduct in everything we do, while holding each other accountable for our actions. While the Code cannot address all situations we may face, together with our purpose and values, it provides us with a north star that guides us in ensuring everything we do is held to the highest ethical, legal and professional standards.

Thank you for your commitment to standing up for what is right and protecting our reputation.

Mario Greco

Group Chief Executive Officer

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Code of Conduct

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Contents

Foreword

Contents

We care
about doing the right thing	4
Living by our purpose and values	5
Acting with integrity	6
Speaking up and reporting concerns	8
Adhering to this Code	9

We care
about business integrity	19
Preventing financial crime	20
• Anti-bribery and anti-corruption	20
• Anti-money laundering,
counter-terrorist financing and
customer tax compliance	21
• Trade and economic sanctions	22
Promoting fair and free markets	23
• Antitrust and fair competition	23
• Dealing in securities	24
Respecting human rights	25

We care
about our colleagues	10
Treating each other with fairness
and understanding	11
Fostering a diverse
and inclusive environment	12
Leading by example	13
Providing a healthy
and safe workplace	14
We care
about our company	26
Retaining and managing records	27
Disclosing conflicts of interest
and external engagements	28
Protecting our assets
and preventing fraud and crime	29
Communicating with external parties	30

	2
	3
We care
about our customers	15
Focusing on the customer	16
Ensuring appropriate
Customer Facing Conduct	17
Protecting data and safeguarding
confidential information	18

We care
about our future	31
Driving change for
a sustainable future	32

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We care about doing the right thing

• because living by our values, making ethical decisions, and speaking up when we see something that does not seem right is crucial for us to maintain the trust of each other, our customers, investors, regulators and society.

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We care	About doing the right thing	About our colleagues	About our customers	About business integrity	About our company	About our future

Living by our purpose and values

Our purpose and values guide the actions that we take both individually and as a business. As our world changes at an unprecedented pace, it is increasingly important to maintain a clear view of what we stand for and why we are in business.

We have the ambition to be one of the most responsible and impactful businesses in the world and we can only achieve this ambition by living our purpose and values every day.

Our purpose

Our world needs actions, not just words. We are in business to create a brighter future together with our customers with sustainable products and services.

By driving proactive prevention and protecting our customers, we empower them with a freedom of choice to explore what is next in their lives and their businesses while maintaining the peace of mind that should they need us, we are here.

Our values

• Optimism
• Determination
• Caring
• Togetherness
• Reliability
• Forward-thinking

Our purpose and values clearly set out why we are in business and provide the foundation for our strategy.

The essence of our business is about customer relationships and the success of our strategy lies in being able to delight our customers with experiences that are uniquely Zurich at every touch point.

More information:

• Our strategy
• Our purpose and values
• Our behaviors*

* internal link

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We care	About doing the right thing	About our colleagues	About our customers	About business integrity	About our company	About our future

Acting with integrity

We conduct ourselves with honesty, fairness, dignity and integrity in our workplace and whenever we act on Zurich's behalf.

Our rules of conduct provide a reference for the decisions we make every day, and our actions and business goals must be consistent with those rules.

We adhere to all laws, rules and regulations of the countries in which Zurich operates, as well as with our internal policies.

We understand and manage the challenges that may arise in our daily work. If we are uncertain about any of the topics covered in this Code, we consult with our manager. Our Legal and Compliance functions are here to help and advise.

Doing the right thing, however, means not only following the rules, but also using our best judgment. Not all situations have a specific guideline to support our actions, nor can this Code address all decisions and potential dilemmas that we may face.

This is why in all of our decisions, we are guided not only by applicable laws and regulations and internal guidelines, but also by what is the right thing to do.

We care	About doing the right thing	About our colleagues	About our customers	About business integrity	About our company	About our future

If unsure what to do when faced with a decision, ask yourself the following questions:

Is it legal?

Consider whether the decision complies with applicable laws and regulation.

Is it the right thing to do?

Consider whether the decision reflects the standards of conduct articulated in this Code and our internal standards and policies, as well as our purpose and values. Ask yourself not only whether you can do something, but whether you should.

Is it in our company's and stakeholders' best interest?

Consider whether the decision honors our commitment to our customers, is respectful of the rights of our colleagues and others we work with, and serves our company's long-term interest. Ask yourself whether the decision places your personal interest in conflict with those of the company or our customers.

Is it reflective of our brand and what Zurich stands for?

Consider whether you would be comfortable if the decision were made public and whether it could hurt our reputation and/ or diminish trust in us, or negatively impact others (e.g., customers, shareholders, colleagues, or the public).

We are all accountable for our own conduct and actions and each of us has a role to play in living up to our values and this Code. Accordingly, if we believe we have been instructed to do something that is illegal, unethical, or violates this Code or any Zurich policy, we raise our concerns. People managers have an added responsibility to lead by example and to set clear expectations around the standards of conduct to which all employees are required to adhere.

Zurich is further committed to forthright, full and prompt disclosure when communicating with regulators, supervisors and governments. This means we are open, honest and cooperative with government investigations or regulatory examinations that involve Zurich, as well as with internal investigations.

If your answer to any of these questions is "No", or if you are in doubt, you should pause, reconsider, and consult with your manager, Legal or Compliance.

Once a government, internal investigation or regulatory examination is underway, we take care to maintain any paper or electronic information relevant to the investigation or examination.

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We care	About doing the right thing	About our colleagues	About our customers	About business integrity	About our company	About our future

Speaking up and reporting concerns

Doing the right thing and speaking up helps protect Zurich, our integrity and our reputation.

Zurich is committed to a Speak Up culture where we appreciate that everyone has a valuable contribution to make and employees and others feel comfortable sharing their views and raising their concerns.

We are encouraged to constructively express our opinions, contribute ideas, or challenge the status quo to help us create a brighter future together. We speak up promptly and report alleged wrongdoing or suspected or actual illegal, fraudulent, improper or unethical conduct ("Integrity Concerns").

There are multiple channels to raise Integrity Concerns, including to people managers, Compliance, Human Resources, or Legal. We reach out to our line managers or Human Resources regarding concerns, suggestions or questions about our jobs or working conditions.

The Zurich Ethics Line may also be used to report concerns either via telephone or online via a web form. Reports can also be made anonymously.

All Integrity Concerns are reviewed by a Triage Committee comprised of representatives from Compliance, Human Resources and Legal.

Confidentiality and no tolerance for retaliation.

We treat all reports of Integrity Concerns confidentially (i.e., on a strict need-to-know basis), including the identity of the person making a report, as well as persons who are the subject of the report and/or part of the investigation.

We do not tolerate retaliation, including threats and attempts of such, against any employee or other person reporting an Integrity Concern with reasonable grounds to believe the information reported was true at the time of reporting.

Protection against retaliation is also extended to those who assist in any investigation or provide information/evidence in the course of any investigation and, where applicable, to other persons.

More information:

• Our Speak Up culture*
• Zurich Ethics Line
• Group Policy on Speaking Up about Integrity Concerns*

* internal link

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We care	About doing the right thing	About our colleagues	About our customers	About business integrity	About our company	About our future

Adhering to this Code

This Code sets out our purpose and values and the minimum standards of conduct expected from us.

We are all expected to read, understand and adhere to the provisions set forth in this Code. This Code is supplemented by other internal policies, some of which are referenced throughout this Code.

Applicability

Our Code applies to everyone at Zurich and its subsidiaries worldwide, including board members and employees including management. Regardless of our role, responsibilities or where we are located in the world, we each do our part to consider the Code and related policies as we go about our daily activities and decisions. We endeavor to work with third parties such as consultants, advisers, suppliers and agents who share our values, and we expect our business partners to adhere to the spirit of our Code and embrace high standards of business conduct.

Annual Personal Awareness and Acknowledgment (APAA)

All of us at Zurich are required to acknowledge that we have read our Code, and that we understand and agree to be bound by the provisions contained in our Code and our other internal policies. We are asked to do so upon hire, and annually after that.

Adherence to the Code is important for all of us

Non-compliance with any provision of this Code may constitute grounds for disciplinary action, up to and including termination of employment. A breach of our Code may also constitute a violation of applicable law, and may result in civil or criminal fines or penalties, including imprisonment, for you.

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We care about our colleagues

• because we know that we can only be successful if we work as a team, and that mutual respect is vital in order for each and every one of us to live up to our full potential.

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Code of Conduct 2022

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