Anti-Bribery Corporate Policy

Transcription

1 Anti-Bribery Crprate Plicy T Whm this Plicy Applies This plicy applies t all emplyees, cntractrs, and members f bards f directrs f member cmpanies f CUNA Mutual Grup and nn-emplyees, including agents, guests, and business partners. Purpse f this Plicy T prhibit acts r perceived acts f bribery, attempted bribery and ther illegal payments t freign fficials. This plicy is designed t cmply with the requirements f the U.S. Freign Crrupt Practices Act (the FCPA ) and the antibribery laws f thse ther jurisdictins in which we d business. These laws generally prhibit bribes, kickbacks, r illegal payments t influence business transactins and require us t maintain accurate bks and recrds and a system f internal cntrls. Key Plicy Terms» In this plicy, a freign fficial includes any persn hlding a traditinal gvernment ffice, a persn emplyed by the gvernment r an agency r ministry f the gvernment, and a persn emplyed by an entity wned r cntrlled by a gvernment (als knwn as a state wned enterprise r SOE ), f a cuntry utside the United States.» In this plicy, anything f value includes, withut limitatin, cash, cash equivalents, payment f travel expenses, prviding services, glf utings r ther entertainment nt custmary t a particular business transactin, assumptin r frgiveness f debt, persnal favrs, ffers f emplyment, and charitable dnatins.» In this plicy, bribery includes the ffering, receiving, r sliciting f anything f value fr the purpse f btaining r retaining business fr r with, r directing business t any persn r entity. What this Plicy Requires*» Cmply with the FCPA, which means yu are prhibited frm the fllwing: Offering, prmising, making, r facilitating the making f payments t a freign fficial fr the actual r perceived purpse f influencing an act r decisin f the fficial r the gvernment they represent; Inducing a freign fficial t use their influence t assist in btaining, facilitating r retaining business r directing business t any persn; r t secure an imprper business advantage; Offering r giving mney r anything f value t any persn r entity when there is a perceptin r a reasn t believe that it will be passed n t a freign fficial r fficial in a public internatinal rganizatin fr a prhibited purpse; Exceeding $100 fr marketing r entertaining expenses directed at a freign fficial; Making a charitable dnatin t an rganizatin utside the United States that has a knwn affiliatin with a freign fficial, withut prir authrizatin frm the Chief Legal Officer; r Entering int, cntinuing r extending any agreement with anther persn r entity t engage in any cnduct therwise prhibited under this plicy. Agreements with persns r entities utside the United States must be reviewed in advance by the Chief Legal Officer r his/her designee in rder t ensure cmpliance with this plicy.» Reprt a suspected vilatin f the FCPA t the hme-ffice based Chief Legal Officer. 1

2 * Please nte: If there is any cnflict between terms f this Crprate Plicy and a related Functinal Plicy, the terms in this Crprate Plicy will cntrl. Vilatins f this plicy may result in discipline up t and including terminatin f emplyment. Plicy Questins r Help This plicy is authrized by the Chief Gvernance Officer. If yu: Observe r experience any intentinal r unintentinal activity that vilates the terms f this plicy, please cntact Chief Legal Officer, Human Resurces at HR4U (4748); , Ext r MB- HR4U. Yu may als cntact ur annymus, cnfidential Speak Freely Line available 24/7 at r at Have questins abut the plicy, review the Anti-Bribery Training fund n Career Academy Have questins cncerning this plicy s cntent, cntact Human Resurces Wuld like t be cnnected with the Plicy Writer, please Crprate Cmpliance at MB- AnnualDisclsur Regulatry r ther Legal Requirements This plicy is intended t supprt CUNA Mutual Grup s cmpliance with the Freign Crrupt Practices Act f 1977, 15 U.S.C. 78dd-1, et seq. Related Plicies r Prcedures Gifts Crprate Plicy Cnflicts f Interest Crprate Plicy Family and Clse Persnal Relatinships Crprate Plicy 2 This dcument was last updated: August 7, 2017

3 Business Cnduct and Regulatry Cmpliance Crprate Plicy T Whm this Plicy Applies This plicy applies t all emplyees, cntractrs, and nn-emplyees, including agents, guests, and business partners. Purpse f this Plicy Fstering a wrk envirnment where expectatins are set fr emplyees t cnduct business with integrity. Key Plicy Terms» In this plicy, a cnflict f interest happens when an emplyee takes an actin, r is perceived t take an actin, that directly r indirectly benefits him r her, a family member, r smene with whm they have a clse persnal relatinship. These actins may have negative cnsequences fr CUNA Mutual Grup.» In this plicy, investigatin means that CUNA Mutual Grup will assign a cmpetent investigatr t review the relevant infrmatin related t an allegatin r cncern, make findings f fact abut allegatin(s), t the extent pssible, and reprt thse findings as necessary and apprpriate t ensure the prmpt and effective crrectin f wrkplace discriminatin, harassment and ther inapprpriate, unethical, r unlawful cnduct. What this Plicy Requires*» Cmply with all applicable laws and regulatins.» Uphld the Crprate Value f Integrity by: Demnstrating the desire t d what s right Cnsistently aligning actins with intent; walk the talk Delivering what is prmised Cmmunicating penly and hnestly Acting ethically in all actins and interactins» Learn abut, understand, and fllw CUNA Mutual Grup s cmpliance framewrk that includes the CUNA Mutual Grup Cde f Cnduct, plicies, and cnflicts f interest disclsure.» Assist in any investigatin f suspected vilatins f CUNA Mutual Grup s Cde f Cnduct, plicies, r cnflicts f interest as requested by representatives f CUNA Mutual Grup r a gvernmental authrity, by prviding hnest and accurate respnses t requests fr infrmatin, dcuments, and tangible items.» Practively disclse any ptential, perceived, r actual cnflicts f interest using the nline disclsure system.» Cmplete required cmpliance training and ther cmpliance-related activities timely and as requested. Training is required fr new emplyees at the time f hire, and peridically thereafter, depending n the type f training and the emplyee s rle.» Seek assistance if yu are unsure hw t fllw this plicy r make decisins with integrity in a given situatin. Use the resurces available t yu, including yur manager, the Chief Ethics and Cmpliance Officer, and ther resurces identified in the Speak Up and Nn-Retaliatin Crprate Plicy. 1

4 * Please nte: If there is any cnflict between terms f this Crprate Plicy and a related Functinal Plicy, the terms in this Crprate Plicy will cntrl. Vilatins f this plicy may result in discipline up t and including terminatin f emplyment. Plicy Questins r Help This plicy is authrized by the Chief Ethics and Cmpliance Officer. If yu: Observe r experience any intentinal r unintentinal activity that vilates the terms f this plicy, please cntact Human Resurces at HR4U (4748); , Ext r MB-HR4U. Yu may als cntact ur annymus, cnfidential Speak Freely Line available 24/7 at r at Have questins cncerning this plicy s cntent, cntact Human Resurces Wuld like t be cnnected with the Plicy Writer, please Crprate Cmpliance at MB- AnnualDisclsur Regulatry r ther Legal Requirements This plicy is intended t supprt CUNA Mutual Grup s cmmitment t cmply with laws enfrced by the Securities and Exchange Cmmissin (SEC), Financial Industry Regulatry Authrity (FINRA), the Natinal Labr Relatins Bard (NLRB) and any State s Department f Insurance (DOI) r Office f the Cmmissiner f Insurance (OCI). This plicy is further intended t supprt CUNA Mutual Grup s cmmitment t cmply with laws prtecting the privacy f individuals Nnpublic Persnal Infrmatin and Prtected Health Infrmatin, including the Gramm-Leach-Bliley Act (GLBA) and the Health Insurance Prtability and Accuntability Act (HIPAA). This plicy is further intended t supprt CUNA Mutual Grup s cmmitment t cmply with Title VII f the Civil Rights Act f 1964, the Age Discriminatin in Emplyment Act (ADEA), the Americans with Disabilities Act (ADA), the Genetic Infrmatin Nndiscriminatin Act (GINA), the Pregnancy Discriminatin Act, the Unifrmed Services Emplyment and Reemplyment Act f 1994 (USERRA), the Emplyee Retirement Incme Security Act (ERISA), the Iwa Fair Emplyment Practices Act (Iwa Cde Chapter 216), the Kansas Act Against Discriminatin (KAAD), the Kansas Age Discriminatin in Emplyment Act (KADEA), the Wiscnsin Fair Emplyment Act (WFEA) the Texas Labr Cde, the Ft. Wrth, TX, anti-discriminatin rdinance, the Madisn, WI, Equal Opprtunities Ordinance, and similar prvisins f applicable Federal and State laws and lcal rdinances that prhibit emplyment discriminatin by private sectr emplyers. Related Plicies r Prcedures Fraud Preventin Crprate Plicy Speak Up and Nn-Retaliatin Crprate Plicy Cnflicts f Interest Crprate Plicy 2 This dcument was last updated: August 7, 2017

5 Cllectins and Slicitatins Crprate Plicy T Whm this Plicy Applies This plicy applies t all emplyees, cntractrs, and members f bards f directrs f member cmpanies f CUNA Mutual Grup and nn-emplyees, including agents, guests, and business partners. Purpse f this Plicy This plicy places limits n Cllectins and Slicitatins activities in rder t maintain a wrk envirnment free frm unnecessary disruptins frm slicitatins and literature distributin in rder t supprt high levels f perfrmance and prductivity in the wrkplace. Key Plicy Terms» In this plicy, cmmercial slicitatin means the sale, attempted sale, request fr participatin r financial supprt, r ther marketing f nn-cuna Mutual Grup prducts and services by emplyees.» In this plicy, charitable slicitatin means requests fr participatin in r financial supprt f charitable activities.» In this plicy, literature distributin means psting r handing ut written infrmatin unrelated t CUNA Mutual Grup s prducts and services by emplyees. What this Plicy Requires*» Avid engaging in cmmercial slicitatin activities during yur wn wrk time r the wrk time f the persn wh is the target f the slicitatin activity, unless prir apprval has been granted by the Chief Human Resurces Officer.» Avid engaging in charitable slicitatin activities during yur wn wrk time r the wrk time f the persn wh is the target f the slicitatin activity, unless prir apprval has been granted by the Chief Human Resurces Officer, r the activity is part f the limited number f Cmpany-authrized cmmunity supprt and charitable fundraising initiatives supprted by Cmmunity Relatins.» Avid engaging in literature distributin in wrk areas ther than yur assigned ffice/wrk statin, unless prir apprval has been granted by the Chief Human Resurces Officer. Use Cmpany bulletin bards nly in the manner cnsistent with psted Bulletin Bard General Guidelines. *Please nte: If there is a cnflict between the terms f this Crprate Plicy and any related Functinal Plicy, the terms in this Crprate Plicy will cntrl. Vilatins f this plicy may result in discipline up t and including terminatin f emplyment. Plicy Questins r Help This plicy is authrized by the Chief Human Resurce Officer. If yu: Observe r experience any intentinal r unintentinal activity that vilates the terms f this plicy, please cntact Human Resurces at HR4U (4748); , Ext r MB-HR4U. Yu may als cntact ur annymus, cnfidential Speak Freely Line available 24/7 at r at Have questins cncerning this plicy s cntent, cntact Human Resurces Wuld like t be cnnected with the Plicy Writer, please Crprate Cmpliance at MB- AnnualDisclsur . 1

6 Related Plicies r Prcedures Charitable Activities Functinal Prcedure Speak Up & Nn-Retaliatin Crprate Plicy 2 This dcument was last mdified: August 7, 2017

7 Cnflicts f Interest Crprate Plicy T Whm this Plicy Applies This plicy applies t all emplyees, cntractrs, and members f bards f directrs f member cmpanies f CUNA Mutual Grup. Purpse f this Plicy Fstering integrity in the wrk envirnment where expectatins are set fr individuals t identify, reprt, and manage ptential, perceived, r real cnflicts f interest. Key Plicy Terms» In this plicy, a cnflict f interest happens when an emplyee takes an actin, r is perceived t take an actin, that directly r indirectly benefits him r her, a family member, r smene with whm they have a clse persnal relatinship. These actins may have negative cnsequences fr CUNA Mutual Grup.» In this plicy, family members are persns currently r previusly related by bld, marriage, and/r adptin.» In this plicy, persns in a clse persnal relatinship are persns wh live in the same husehld and/r persns engaged in a rmantic r sexual relatinship. What this Plicy Requires*» Avid cnflicts f interest that d, r culd be perceived t, influence yur respnsibilities, judgment, bjectivity, r lyalty t CUNA Mutual Grup.» Avid engaging in activities where a cnflict f interest des r culd have the appearance f cmprmising yur ability t bjectively advance the interests f CUNA Mutual Grup, including, but nt limited t: Having a financial interest in a CUNA Mutual Grup cmpetitr, supplier, r custmer (except fr insignificant stck interests in publicly-held cmpanies) Taking part in any business decisin at CUNA Mutual Grup that invlves a cmpany in which yu, yur family member, r a persn in a clse persnal relatinship with yu has a financial interest Wrking fr, advising, r serving as a member f the bard f directrs fr a cmpetitr f CUNA Mutual Grup Wrking fr, advising, r serving as a member f the bard f directrs fr a credit unin if yu are a Sales emplyee directly assigned t credit unin accunts If yur rle des nt include direct r indirect sales, yur cnflict may be manageable Receiving persnal discunts r ther benefits frm suppliers r custmers that are nt available t all CUNA Mutual Grup emplyees and/r the general public Accepting persnal payments fr services that relate t CUNA Mutual Grup s business Taking a business pprtunity fr yurself that belngs t CUNA Mutual Grup» Receive prir apprval fr the fllwing activities which culd be perceived as a cnflict f interest: Any utside activity that yu will be paid fr, including a secnd jb that relates t CUNA Mutual Grup s 1

8 business, invlves wrk similar t yur jb respnsibilities at CUNA Mutual Grup, r invlves use f any CUNA Mutual Grup resurces r intellectual prperty Outside business activity, regardless f pay, that relates t CUNA Mutual Grup s business r invlves wrk similar t yur jb respnsibilities at CUNA Mutual Grup, where yu are functining as a directr, fficer, advisry bard member, wner, r cnsultant Psitins with trade assciatins, prfessinal assciatins, r similar rganizatins that prvide infrmatin and supprt relevant t yur jb respnsibilities at CUNA Mutual Grup are nt subject t this requirement and d nt need t be pre-apprved» All emplyees and external directrs are required t practively disclse any ptential, perceived, r actual cnflicts f interest using the nline disclsure system. What Happens if I Reprt a Cnflict f Interest?» The Chief Ethics and Cmpliance Officer r their designee is respnsible fr managing the disclsure prcess that determines the existence and manageability f any ptential, perceived, r actual cnflicts f interest fr all emplyees and external directrs. If the cnflict f interest can be effectively managed, the individual(s) invlved in the cnflict, as well as their manager, will be prvided expectatins t effectively manage the cnflict f interest. If the cnflict f interest cannt be effectively managed, the individual(s) invlved in the cnflict will need t discntinue the cnflicting activity r relatinship, r resign their emplyment in rder t avid the cnflict.» Fr directrs serving n the varius f Bards f Directrs f CUNA Mutual Grup entities, the designated cmmittee, r the full Bard f Directrs f that entity, are respnsible fr determining the existence and manageability f any actual r perceived cnflicts f interest fr thse external directrs. In these situatins, the Chief Ethics and Cmpliance Officer r their designee manages the annual disclsure prcess in cnjunctin with the Crprate Secretary f each entity. * Please nte: If there is any cnflict between terms f this Crprate Plicy and a related Functinal Plicy, the terms in this Crprate Plicy will cntrl. Vilatins f this plicy may result in discipline up t and including terminatin f emplyment. Plicy Questins r Help This plicy is authrized by the Chief Ethics and Cmpliance Officer. If yu: Observe r experience any intentinal r unintentinal activity that vilates the terms f this plicy, please cntact Human Resurces at HR4U (4748); , Ext r MB-HR4U. Yu may als cntact ur annymus, cnfidential Speak Freely Line available 24/7 at r at Have questins cncerning this plicy s cntent, cntact Human Resurces Wuld like t be cnnected with the Plicy Writer, please Crprate Cmpliance at MB- AnnualDisclsur Regulatry r ther Legal Requirements This plicy is intended t supprt CUNA Mutual Grup s cmmitment t cmply with Financial Industry Regulatry Authrity (FINRA) and Securities and Exchange Cmmissin (SEC) regulatry requirements fr mitigating and managing cnflicts f interest. 2 This dcument was last updated: August 7, 2017

9 Related Plicies r Prcedures Family and Clse Persnal Relatinships Crprate Plicy Gifts Crprate Plicy Business Cnduct and Regulatry Cmpliance Crprate Plicy 3 This dcument was last updated: August 7, 2017

10 Equal Emplyment Opprtunity Crprate Plicy T Whm this Plicy Applies This plicy applies t all emplyees, cntractrs, and members f bards f directrs f member cmpanies f CUNA Mutual Grup. Purpse f this Plicy T maintain a wrkplace that is free frm unlawful discriminatin and respectful f emplyees diverse perspectives, and t ensure that reasnable accmmdatins are made available. Key Plicy Terms» In this plicy, prtected characteristics means a persn s race, clr, creed, religin, sex, gender, disability, age, natinal rigin, citizenship status, marital status, sexual rientatin, military r veteran status, pregnancy, childbirth, r related medical cnditins, as defined by applicable law, genetic infrmatin, gender identity r expressin, ancestry, medical cnditin, r any ther status prtected by applicable federal, state, r lcal laws and rdinances.» In this plicy, wrk-related activities include, withut limitatin, recruitment, emplyment, prmtin, transfer, training, wrking cnditins, wages and salary administratin, and emplyee benefits. What this Plicy Requires*» Make all emplyment-related decisins withut taking int accunt any persn s prtected characteristics.» Demnstrate respect fr peple s prtected characteristics and seek ut and encurage expressin f diverse perspectives in wrk-related activities.» CUNA Mutual Grup will make thse reasnable accmmdatins required by law t enable a qualified persn with a disability t perfrm the essential functins f a jb. *Please nte: If there is a cnflict between the terms f this Crprate Plicy and any related Functinal Plicy, the terms in this Crprate Plicy will cntrl. Vilatins f this plicy may result in discipline up t and including terminatin f emplyment. Plicy Questins r Help This plicy is authrized by the Chief Human Resurce Officer. If yu: Need t request a disability accmmdatin, please cntact Human Resurces. Observe r experience any intentinal r unintentinal activity that vilates the terms f this plicy, please cntact Human Resurces at HR4U (4748); , Ext r MB-HR4U. Yu may als cntact ur annymus, cnfidential Speak Freely Line available 24/7 at r at Have questins cncerning this plicy s cntent, cntact Human Resurces Wuld like t be cnnected with the Plicy Writer, please Crprate Cmpliance at MB- AnnualDisclsur . 1

11 Regulatry r Other Legal Requirements This plicy is intended t supprt CUNA Mutual Grup s cmmitment t cmply with Title VII f the Civil Rights Act f 1964, the Age Discriminatin in Emplyment Act (ADEA), the Americans with Disabilities Act (ADA), the Genetic Infrmatin Nndiscriminatin Act (GINA), the Pregnancy Discriminatin Act, the Unifrmed Services Emplyment and Reemplyment Act f 1994 (USERRA), the Emplyee Retirement Incme Security Act (ERISA), the Iwa Fair Emplyment Practices Act (Iwa Cde Chapter 216), the Kansas Act Against Discriminatin (KAAD), the Kansas Age Discriminatin in Emplyment Act (KADEA), the Wiscnsin Fair Emplyment Act (WFEA) the Texas Labr Cde, the Ft. Wrth, TX, anti-discriminatin rdinance, the Madisn, WI, Equal Opprtunities Ordinance, and similar prvisins f applicable Federal and State laws and lcal rdinances that prhibit emplyment discriminatin by private sectr emplyers. Related Plicies r Prcedures Speak Up & Nn-Retaliatin Crprate Plicy Custmer Accessibility Functinal Plicy 2 This dcument was last updated: August 7, 2017

12 Expenses Crprate Plicy T Whm this Plicy Applies This plicy applies t all emplyees. Purpse f this Plicy T prtect the CUNA Mutual Grup s assets by requiring that emplyees incur nly thse business expenses that are reasnable, business related and effectively manage risk. What this Plicy Requires*» Incur nly thse reasnable business expenses needed t cnduct CUNA Mutual Grup s business, prtecting cmpany funds as thugh they were yur wn.» Understand and fllw yur authrity limits per the President s Delegatin f Authrity.» Use yur crprate credit card r CUNA Mutual Grup s payables/disbursement prcess fr all expenses. Reimbursement is limited t incidental cash transactins and must be prcessed thrugh the crprate credit card system.» Use CUNA Mutual Grup s designated travel agency and preferred vendrs fr all travel bkings, unless cnference rates r ther reduced-rate accmmdatins are available.» Obtain and submit prper expense supprt, such as receipts and/r invices, descriptins and accunt cding, n a timely basis and at least mnthly. Detailed receipts are required fr all transactins f $75 r mre.» Fllw any departmental plicy, prcedure r practice which may be mre restrictive than this plicy and related prcedures.» Gift cards and gift certificates are nt t be purchased using yur crprate credit card and are nt t be used fr emplyee recgnitin. Gift cards are nly an acceptable expense when they are apprved by yur manager and requested thrugh the Crprate Gift Card prgram that allws gift cards t be given t external custmers nly. Managers wh wish t prvide emplyee recgnitin shuld cntact Human Resurces as indicated belw.» D nt use yur crprate credit card, the CUNA Mutual Grup s payables/disbursements prcess, r any ther CUNA Mutual Grup resurce(s) fr persnal expenses, unlawful items, leisure activities, adult entertainment r any item which wuld be incnsistent with ur Cde f Cnduct, plicies r prcedures.» D nt incur r seek reimbursement fr any expenses f a persnal nature r related t a guest (e.g., spuse, child, etc.) accmpanying yu n business travel.» D nt make any cntributins t plitical activities n behalf f CUNA Mutual Grup.» If yu are unsure f what t d, yu shuld discuss the issue with yur immediate supervisr/manager. * Please nte: If there is any cnflict between terms f this Crprate Plicy and a related Functinal Plicy, the terms in this Crprate Plicy will cntrl. Vilatins f this plicy may result in discipline up t and including terminatin f emplyment. 1

13 Plicy Questins r Help This plicy is authrized by the Chief Accunting Officer. If yu: Observe r experience any intentinal r unintentinal activity that vilates the terms f this plicy, please cntact Human Resurces at HR4U (4748); , Ext r MB-HR4U. Yu may als cntact ur annymus, cnfidential Speak Freely Line available 24/7 at r at Have questins cncerning this plicy s cntent, cntact Human Resurces. Wuld like t be cnnected with the Plicy Writer, please Crprate Cmpliance at MB- AnnualDisclsur . Regulatry r ther Legal Requirements IRS Regulatins Related Plicies r Prcedures Meals and Entertainment Functinal Plicy Travel Functinal Plicy Cntributins t Plitical Activities Functinal Plicy Gifts Crprate Plicy 2 This dcument was last updated: August 7, 2017

14 Family and Clse Persnal Relatinships Crprate Plicy T Whm this Plicy Applies This plicy applies t all emplyees, cntractrs, and members f bards f directrs f member cmpanies f CUNA Mutual Grup and nn-emplyees, including agents and business partners. Purpse f this Plicy T prevent cnflicts f interest r the appearance f cnflicts f interest that result when bard members and/r certain executives are nt independent frm ther emplyees; t prevent cnflicts f interest r the appearance f cnflicts f interest that result when emplyees wrking in a direct r indirect supervisry relatinship are nt independent frm each ther. Key Plicy Terms» In this plicy, family members are persns currently r previusly related by bld, marriage, and/r adptin.» In this plicy, persns in a clse persnal relatinship are persns wh live in the same husehld and/r persns engaged in a rmantic r sexual relatinship.» In this plicy, a cnflict f interest happens when an emplyee takes an actin, r is perceived t taken an actin, that directly r indirectly benefits him r her, a family member, r smene whm they have a clse persnal relatinship. Fr mre infrmatin abut Cnflicts f Interest, see the Cnflicts f Interest Crprate Plicy in the Related Plicies r Prcedures sectin belw. What this Plicy Requires*» D nt ffer, accept, r cntinue in a rle if it wuld result in the emplyment f a family member f, r persn in a clse persnal relatinship with: A persn wh directly r indirectly supervises that rle, regardless f the number f layers f management in between A Member f the Bard f Directrs f CUNA Mutual Hlding Cmpany r its direct r indirect subsidiary A Member f the Executive Cuncil An fficer emplyed in the Legal, Gvernance, Risk & Assurance r Human Resurces Departments» D nt ffer, accept, r cntinue in a rle if it wuld result in an emplyee prviding prfessinal advice r regulatry r cmpliance versight (e.g., a rle in Legal, Gvernance, Risk & Assurance, Crprate Cmpliance r Human Resurces) t a business area where a family member r persn in a clse persnal relatinship is emplyed.» Emplyees in rles with authrity t make management decisins r vendr selectin may nt make such decisins when there may be a significant impact n the emplyment r financial supprt f a family member r a persn in a clse persnal relatinship.» D nt enter int r cntinue a temprary emplyee r cntractr relatinship that wuld vilate this plicy if the temprary emplyee r cntractr were a CUNA Mutual Grup emplyee.» Yu are required t disclse any ptential cnflicts yu have related t this plicy t the Chief Human Resurces Officer at any time, and annually thrugh the Annual Cnflicts f Interest Disclsure and Plicy Cmpliance Certificatin prcess. Emplyees may disclse such cnflicts t a member f the Emplyee and Labr Relatins team, wh will assist with additinal ntificatins. 1

15 » If yu expect a future change in family r relatinship status that wuld result in a vilatin f this plicy, ntify the Chief Human Resurces fficer r the Chief Ethics and Cmpliance Officer prir t the change ccurring. Hw Disclsures Will Be Addressed» CUNA Mutual Grup will address situatins where an expected future change in family r relatinship status may result in a vilatin f this plicy. The situatin will be reviewed t determine whether the cnflict f interest can be effectively managed. If nt, it may be necessary fr ne f the peple invlved t be reassigned r asked t resign their emplyment in rder t avid the cnflict. * Please nte: If there is any cnflict between terms f this Crprate Plicy and a related Functinal Plicy, the terms in this Crprate Plicy will cntrl. Vilatins f this plicy may result in discipline up t and including terminatin f emplyment. Plicy Questins r Help This plicy is authrized by the Chief Human Resurce Officer. If yu: Observe r experience any intentinal r unintentinal activity that vilates the terms f this plicy, please cntact Human Resurces at HR4U (4748); , Ext r MB-HR4U. Yu may als cntact ur annymus, cnfidential Speak Freely Line available 24/7 at r at Have questins cncerning this plicy s cntent, cntact Human Resurces. Wuld like t be cnnected with the Plicy Writer, please Crprate Cmpliance at MB- AnnualDisclsur . Related Plicies r Prcedures Cnflicts f Interest Crprate Plicy 2 This dcument was last updated: August 7, 2017

16 Fraud Preventin and Anti-Crruptin Crprate Plicy T Whm this Plicy Applies This plicy applies t all emplyees, and members f bards f directrs f member cmpanies f CUNA Mutual Grup, and nn-emplyees, including agents and business partners. Purpse f this Plicy The purpse f this plicy is t prvide guidelines fr the preventin, detectin, and reprting f fraudulent r crrupt acts. Key Plicy Terms» In this plicy, fraud is defined as (a) the use f deceptin with the intent f pursuing persnal interests and causing lss t the prper interests f CUNA Mutual Grup, (b) the illegitimate pursuit f inapprpriate cmpany interests fr persnal gain, and (c) the intentinal distrtin f financial statements r ther recrds by persns internal r external t the cmpany which is carried ut t cnceal misapprpriatin f assets r persnal gain. Sme examples f fraud r fraudulent behavir include, but are nt limited t: Using crprate interests fr persnal gain Misapprpriatin f assets, embezzlement and theft Payment r receipt f bribes, kickbacks r ther inapprpriate payments Participatin in sham r fraudulent transactins Deceptive, misleading r false statements abut crprate transactins Frgery r alteratin f accunting recrd r vuchers Failing t keep CUNA Mutual Grup s Cnfidential Cmpany Infrmatin (CCI) r trade secrets cnfidential Nn-disclsure f material infrmatin needed fr an infrmed investment decisin Other fraudulent behavirs causing lss t the CUNA Mutual Grup s interests» In this plicy, crruptin is the abuse f pwer r psitin fr persnal gain r fr the benefit f anther persn r entity. What this Plicy Requires*» Learn abut the types f fraudulent activity that can be present in yur area f jb respnsibility, and mnitr business activities, transactins, and cmmunicatins fr indicatrs f fraud and/r crruptin while yu are ding yur jb.» Learn abut and understand the fraud risk assessment and cntrls in place fr yur business area.» Prmptly reprt fraudulent, dishnest, r crrupt practices accrding t the Speak Up & Nn-Retaliatin Plicy. Reprt suspected fraud and/r crruptin using the cntact inf in the Plicy Questins r Help bx belw.» Assist in any investigatin f suspected vilatins as requested by representatives f CUNA Mutual Grup r a gvernmental authrity. 1

17 » Cmply with the reprting and disclsure prvisins f the Vilent Crime Cntrl and Law Enfrcement Act f 1994 (see Regulatry Requirements). D nt knwingly file a false statement r prperty valuatin in cnnectin with any financial reprts r dcuments with an insurance regulatr.» D nt embezzle r misapprpriate mney, funds, premiums, credits, r ther prperty frm a member cmpany f CUNA Mutual Grup.» D nt make false statements regarding the financial cnditin f an insurance cmpany with the intent t deceive any individual r regulatr regarding the financial cnditin r slvency f a member cmpany f CUNA Mutual Grup.» D nt bstruct r impede the investigatins f insurance regulatrs by threats, frce, r by threatening letter r cmmunicatin.» Cmply with the federal Vilent Crime Cntrl and Law Enfrcement Act f 1994, which prhibits hiring r cntinuing t emply a persn in the business f insurance if the persn has ever engaged in cnduct prhibited under this Plicy, r if they have been cnvicted f a felny invlving dishnesty r breach f trust. A persn therwise prhibited frm emplyment in the business f insurance may be emplyed if they first present written cnsent frm the apprpriate insurance regulatry fficial. Emplyees must practively disclse prhibited cnduct and cnvictins t the Chief Ethics and Cmpliance Officer using the nline disclsure system. * Please nte: If there is any cnflict between terms f this Crprate Plicy and a related Functinal Plicy, the terms in this Crprate Plicy will cntrl. Vilatins f this plicy may result in discipline up t and including terminatin f emplyment. Plicy Questins r Help This plicy is authrized by the Chief Gvernance Officer. If yu: Observe r experience any intentinal r unintentinal activity that vilates the terms f this plicy, please cntact Human Resurces at HR4U (4748); , Ext r MB-HR4U. Yu may als cntact ur annymus, cnfidential Speak Freely Line available 24/7 at r at Have questins cncerning this plicy s cntent, cntact Human Resurces Wuld like t be cnnected with the Plicy Writer, please Crprate Cmpliance at MB- AnnualDisclsur Regulatry r ther Legal Requirements This plicy is intended t supprt CUNA Mutual Grup s cmpliance with the Vilent Crime Cntrl and Law Enfrcement Act f 1994, 18 U.S.C and This plicy is further intended t supprt CUNA Mutual Grup s cmmitment t cmply with laws enfrced by the Department f Insurance (DOI) r Office f the Cmmissiner f Insurance (OCI) in all States where it des business. Related Plicies r Prcedures Anti-Bribery Crprate Plicy Speak Up and Nn-Retaliatin Crprate Plicy Cnflicts f Interest Crprate Plicy 2 This dcument was last updated: August 7, 2017

18 Gifts Crprate Plicy T Whm this Plicy Applies This plicy applies t all emplyees, cntractrs, and members f bards f directrs f member cmpanies f CUNA Mutual Grup and nn-emplyees, including agents, guests, and business partners. Purpse f this Plicy Fstering integrity in the wrk envirnment where expectatins are set fr emplyees t avid the reality r appearance f actins that are nt in the cmpany s best interest r create a quid pr qu with c-wrkers and/r third parties, including but nt limited t custmers, vendrs, suppliers, cnsultants, and gvernment emplyees. Key Plicy Terms» In this plicy, a gift is a thing f value given withut expectatin f payment, either by an emplyee t a third party, r by a third party t an emplyee. Gifts d nt include nminal prmtinal materials f a general nature, such as pens, cffee mugs, t-shirts, r ther similar items. Gifts d include business meals and entertainment as well as registratin fees fr educatinal events such as cnferences and seminars.» In this plicy, business meals and entertainment include fd, beverage, hspitality, entertainment, and amusement that are prvided in cnnectin with an actual r prspective business relatinship, either by ne r mre emplyees t a third party r representative(s) f a third party, r by a third party r representative(s) f a third party t ne r mre emplyees.» In this plicy, quid pr qu means a thing f value that is given with expectatin f anther thing f value being given in return. What this Plicy Requires*» In the event yu give r accept gifts that are related t yur jb respnsibilities r CUNA Mutual Grup s business, d s nly in a way that des nt create an appearance that the giver intended t influence a business decisin r create a quid pr qu. If at any time yu are unsure f the requirements f this plicy, please discuss with yur manager r cntact Human Resurces as utlined belw in Plicy Questins r Help.» Giving gifts Prhibited: Cash r securities in any amunt Gift cards t emplyees Gift cards and gift certificates are nt t be used fr emplyee recgnitin. Managers wh wish t prvide emplyee recgnitin shuld cntact Human Resurces as utlined belw in Plicy Questins r Help Invlving a gvernment emplyee, candidate fr public ffice, r a party engaged in a tender r cmpetitive bidding prcess Creates an appearance that it was intended t influence a business decisin r create a quid pr qu Business meals and entertainment nt attended by hst Travel and ldging expenses Invlving gifts r entertainment that are indecent, sexually riented, r d nt cmply with CUNA Mutual Grup's cmmitment t integrity, therwise might negatively affect ur reputatin, r cause anther persn t vilate the plicies and standards f their emplyer Business meals and entertainment invlving a member f Cngress, Cngressinal staff, r high-ranking member f the Executive Branch withut prir apprval by the SVP f Legislative and Crprate Affairs 1

19 Allwed: Related t business needs with dcumented business purpse Transparent t CUNA Mutual Grup Gift cards t external custmers via the Gift Card Prgram CUNA Mutual Grup has a Crprate Gift Card prgram that allws gift cards t be given t external custmers nly. See Crprate Gift Card Prgram link belw in Related Plicies and Prcedures.» Accepting gifts Prhibited: Cash r securities in any amunt Creates an appearance that it was intended t influence a business decisin r create a quid pr qu Invlving a gvernment emplyee, candidate fr public ffice, r a party engaged in a tender r cmpetitive bidding prcess Business meals and entertainment nt attended by the hst Travel and ldging expenses Invlving gifts r entertainment that are indecent, sexually riented, r d nt cmply with CUNA Mutual Grup's cmmitment t integrity, therwise might negatively affect ur reputatin, r cause anther persn t vilate the plicies and standards f their emplyer Allwed: Related t business needs with dcumented business purpse Transparent t CUNA Mutual Grup» In the event yu receive a prhibited gift, the gift must be declined r dnated t charity. T dnate, please cntact a Cmmunity Relatins team member. Perishable gifts that cannt be dnated must be shared with all emplyees f the recipient s department.» Yur department r business area may have mre restrictive plicies r prcedures fr gifts and business meals and entertainment. Emplyees in these areas are expected t be familiar with and fllw their department r business area s mre restrictive plicy r prcedure. * Please nte: If there is any cnflict between terms f this Crprate Plicy and a related Functinal Plicy, the terms in this Crprate Plicy will cntrl. Vilatins f this plicy may result in discipline up t and including terminatin f emplyment. Plicy Questins r Help This plicy is authrized by the Chief Ethics and Cmpliance Officer. If yu: Observe r experience any intentinal r unintentinal activity that vilates the terms f this plicy, please cntact Human Resurces at HR4U (4748); , Ext r MB-HR4U. Yu may als cntact ur annymus, cnfidential Speak Freely Line available 24/7 at r at Have questins cncerning this plicy s cntent, cntact Human Resurces Wuld like t be cnnected with the Plicy Writer, please Crprate Cmpliance at MB- AnnualDisclsur 2 This dcument was last updated: August 7, 2017

20 Regulatry r ther Legal Requirements This plicy is generally intended t supprt CUNA Mutual Grup s cmpliance with laws enfrced by the Securities and Exchange Cmmissin (SEC), Financial Industry Regulatry Authrity (FINRA), and any State s Department f Insurance (DOI) r Office f the Cmmissiner f Insurance (OCI). This plicy further supprts CUNA Mutual Grup s cmpliance with the Freign Crrupt Practices Act f 1977, 15 U.S.C. 78dd-1, et seq. and applicable state and federal laws relating t plitical cntributins, electins, and assciated public reprting. Related Plicies r Prcedures Cnflicts f Interest Crprate Plicy Expenses Crprate Plicy Crprate Gift Card Prgram 3 This dcument was last updated: August 7, 2017

21 Insider Trading Prhibitin Crprate Plicy T Whm this Plicy Applies This plicy applies t all emplyees, cntractrs, and members f bards f directrs f member cmpanies f CUNA Mutual Grup, and nn-emplyees, including agents, guests, and business partners. Purpse f this Plicy T prevent persns frm using r sharing inside infrmatin gained during their emplyment r assciatin with CUNA Mutual Grup t influence decisins relating t the purchase r sale f securities. Key Plicy Terms» Inside infrmatin is material infrmatin, as defined belw, which is nt generally available t the investing public. Inside infrmatin can be btained frm many different surces, and includes infrmatin btained cnfidentially during the curse f emplyment/assciatin frm research, custmers and suppliers.» Material infrmatin is infrmatin that a reasnable investr wuld likely cnsider imprtant in deciding whether t purchase r sell a security. If infrmatin wuld influence a reasnable investr t want t buy r sell securities, the infrmatin is cnsidered material. T be cnsidered material, infrmatin des nt have t be certain. Infrmatin that an event may happen, is prbable, r is likely may be cnsidered material.» Tip The act f prviding inside infrmatin abut a publicly-traded cmpany t a persn wh is nt authrized t have the infrmatin.» Access persn Includes all emplyees f CUNA Mutual Grup and thse ther persns listed in the T Whm this Plicy Applies sectin wh are in a psitin t explit inside infrmatin (e.g., fficers f MCA, persns with access t inside infrmatin regarding purchase r sale f securities within CUNA Mutual Grup prtfli, etc.) What this Plicy Requires*» Obtain pre-apprval f persnal securities trading if yu are an access persn.» D nt buy, sell, r recmmend the purchase r sale f securities if yu have inside infrmatin related t thse securities.» D nt disclse r publish inside infrmatin r tips utside CUNA Mutual Grup r t a CUNA Mutual Grup emplyee r cntractr wh des nt have a jb-related need t knw it.» D nt engage in securities trading in an industry r market abut which yu have inside infrmatin that has nt been made available t the general public thrugh established channels and the infrmatin has been absrbed by the marketplace and the public. * Please nte: If there is any cnflict between terms f this Crprate Plicy and a related Functinal Plicy, the terms in this Crprate Plicy will cntrl. Vilatins f this plicy may result in discipline up t and including terminatin f emplyment. Plicy Questins r Help This plicy is authrized by the Senir Vice President, Wealth Management. If yu: Observe r experience any intentinal r unintentinal activity that vilates the terms f this plicy, please cntact Human Resurces at HR4U (4748); , Ext r MB-HR4U. Yu may als cntact ur annymus, cnfidential Speak Freely Line available 24/7 at r at Have questins regarding inside infrmatin, cntact the Chief Legal Officer r MCA Chief Cmpliance Officer. 1

22 Have questins cncerning this plicy s cntent, cntact Human Resurces. Wuld like t be cnnected with the Plicy Writer, please Crprate Cmpliance at MB- AnnualDisclsur . Related Plicies r Prcedures Business Cnduct and Regulatry Cmpliance Crprate Plicy 2 This dcument was last updated: August 7, 2017

23 Intellectual Prperty Crprate Plicy T Whm this Plicy Applies This plicy applies t all emplyees, cntractrs, and members f bards f directrs f member cmpanies f CUNA Mutual Grup, and nn-emplyees, including agents and business partners. Purpse f this Plicy T establish, prtect, maintain and defend CUNA Mutual Grup s intellectual prperty and the rights assciated with such prperty; and t respect the intellectual prperty rights f thers. Usage f CUNA Mutual Grup s intellectual prperty in an apprpriate and cnsistent manner is critical t the success f the enterprise. Imprper use f third-party intellectual prperty expses CUNA Mutual Grup t legal, financial and reputatinal risks. Key Plicy Terms» In this plicy, intellectual prperty means a wrk, writing, idea, prgram, prcess r inventin that is the result f human ideas r creativity, t which a persn r entity has legal rights and fr which a persn r entity may apply fr a patent, cpyright, r trademark. Intellectual prperty includes, withut limitatin, cpyrighted material, brands, trademarks, knw-hw, images, phtgraphy, vides, music, lgs, prgrams, dcuments, frms, tls, and ther wrk.» In this plicy, third-party intellectual prperty is intellectual prperty wned by a persn r entity ther than CUNA Mutual Grup.» In this plicy, use f intellectual prperty includes using, re-using, publishing, re-publishing, mdifying, creating derivative wrks, distributing, and reprducing phtgraphs, audi and/r vide recrdings in accrdance with the related plicies and prcedures listed belw.» In this plicy, trade secrets are infrmatin pssessed by CUNA Mutual Grup, including frmulas, patterns, cmpilatins, prgrams, devices, methds, techniques, r prcesses, that derive independent ecnmic value, actual r ptential, frm nt being generally knwn t, and nt being readily ascertainable by prper means by ther persns r entities wh can btain ecnmic value frm its disclsure r use, and are subject t CUNA Mutual Grup s reasnable effrts t maintain their secrecy. The definitin f trade secrets is intended as the term is defined in the Unifrm Trade Secrets Act (USTA), cdified at Wiscnsin Statutes What this Plicy Requires*» Acknwledge and understand that yur wrk, whether it be dcuments, cde, prgrams, algrithms, analyses, audi r vide recrdings, cllectins f data, r any ther infrmatin created, cmpiled, r prepared fr CUNA Mutual Grup r n its behalf during the curse f yur emplyment is the exclusive intellectual prperty f CUNA Mutual Grup, unless there is a written agreement signed by yu and an authrized representative f CUNA Mutual Grup that states therwise.» Wrk with the Legal Department when cntracting with anther persn r entity t create deliverables and/r perfrm services fr CUNA Mutual Grup t ensure prtectin f CUNA Mutual Grup s intellectual prperty.» Secure the apprpriate rights/license(s) prir t using, in the curse f yur jb duties with CUNA Mutual Grup, third-party intellectual prperty.» Be familiar and cmply with the unique usage requirements f CUNA Mutual Grup s and third-parties intellectual prperty (see Related Plicies r Prcedures). Failure t fllw these requirements culd cause a lss r harm t CUNA Mutual Grup. 1

24 » Cperate with CUNA Mutual Grup relating t any additinal measures that need t be taken t secure CUNA Mutual Grup s wnership f any intellectual prperty, including but nt limited t, executing assignments, applicatins, r ther dcuments as directed by CUNA Mutual Grup.» D nt use within r disclse t CUNA Mutual Grup, any intellectual prperty wned by a previus emplyer unless CUNA Mutual Grup is prperly authrized.» In the case f emplyees, d nt use any intellectual prperty yu have independently develped, utside f wrk, using yur wn resurces, withut prir written apprval frm CUNA Mutual Grup.» D nt disclse any f CUNA Mutual Grup s trade secrets, whether learned while perfrming yur jb duties r therwise, t persns r entities that are nt authrized t have them. Hwever, pursuant t the Defend Trade Secrets Act (DTSA), emplyees and cntractrs are permitted under this plicy, and the emplyee is nt therwise liable under any federal r state trade secrets laws, if they disclse a CUNA Mutual Grup trade secret under the fllwing circumstances: The disclsure f a trade secret is made, cnfidentially, t federal, state r lcal gvernment fficials, r t the persn s wn attrney, fr the purpse f reprting a suspected vilatin f law, r respnding t requests fr infrmatin in cnnectin with a gvernment investigatin f a suspected vilatin f law; the disclsure f a trade secret is made in a dcument filed in a lawsuit r ther prceeding, and the filing is made under seal; r the disclsure ccurs in the filing f a lawsuit that alleges the emplyee was retaliated against fr reprting a suspected vilatin f law, r, in cnnectin with such a lawsuit, r in a related a curt prceeding, s lng as any dcuments cntaining the trade secret are filed under seal and any ther disclsure f the trade secrets is dne nly pursuant t a curt rder. * Please nte: If there is any cnflict between terms f this Crprate Plicy and a related Functinal Plicy the terms in this Crprate Plicy will cntrl. If there is any cnflict between terms f this Crprate Plicy and a cntractual Agreement, the Agreement shall cntrl. Vilatins f this plicy may result in discipline up t and including terminatin f emplyment. Plicy Questins r Help This plicy is authrized by the Chief Legal Officer. If yu: Observe r experience any intentinal r unintentinal activity that vilates the terms f this plicy, please cntact Human Resurces at HR4U (4748); , Ext r MB-HR4U. Yu may als cntact ur annymus, cnfidential Speak Freely Line available 24/7 at r at Have questins cncerning this plicy s cntent, cntact Human Resurces. Wuld like t be cnnected with the Plicy Writer, please Crprate Cmpliance at MB- AnnualDisclsur . Regulatry r ther Legal Requirements This plicy is intended t supprt CUNA Mutual Grup s effrts t prtect its intellectual prperty assets, which in turn are gverned by federal laws and regulatins including the Trademark Act f 1946, as amended, and related statutry sectin, United States Cde Title 35 Patents, United States Cde Title 17 Cpyrights, and Title 37 - Cde f Federal Regulatins Patents, Trademarks, and Cpyrights. This plicy is further intended t avail CUNA Mutual Grup f the prtectins available under the Defend Trade Secrets Act (DTSA) f This dcument was last updated: August 7, 2017

25 Related Plicies r Prcedures Infrmatin Handling CCI Functinal Plicy Privacy Crprate Plicy 3 This dcument was last updated: August 7, 2017

26 Preventin f Wrkplace Vilence Crprate Plicy T Whm this Plicy Applies This plicy applies t all emplyees, cntractrs, and members f bards f directrs f member cmpanies f CUNA Mutual Grup, and nn-emplyees, including agents, guests, and business partners. Purpse f this Plicy T maintain a safe wrk envirnment free frm acts r threats f vilence r physical harm and ther threatening r intimidating behavir. Key Plicy Terms» In this plicy, vilent, threatening r intimidating behavir means any behavir that des r is reasnably perceived as likely t cause physical r mental harm t anther persn, including but nt limited t: A direct, indirect, implied, verbal r written threat f vilence. Reference t the use f weapn(s) t harm neself r thers. Thrwing bjects (regardless f size r type) at anther persn r therwise in a vilent, threatening r intimidating manner. Physically tuching anther emplyee in an intimidating, malicius r harassing manner. This includes but is nt limited t, such acts as hitting, slapping, pking, kicking, pinching, grabbing and pushing. Malicius physical intimidatin f thers. Bullying r ther abusive cnduct. This includes but is nt limited t cnduct that a reasnable persn wuld find hstile, ffensive, and unrelated t an emplyer s legitimate business interests, such as repeated inflictin f verbal abuse; verbal r physical cnduct that a reasnable persn wuld find threatening, intimidating, r humiliating; r the gratuitus sabtage r undermining f a persn s wrk perfrmance. Statements indicating apprval f the use f vilence t reslve prblems. Pssessin r use f unauthrized firearms r ther dangerus weapns in r arund cmpany premises. This includes but is nt limited t the grunds, parking lts and buildings, except t the extent that lcal jurisdictins permit persns with apprpriate firearm licenses t transprt r stre firearms in their lcked vehicles in an emplyee parking lt. What this Plicy Requires*» Treat all CUNA Mutual Grup emplyees, custmers, clients, cntractrs, vendrs, and visitrs in nnvilent manner and avid engaging in, apprving f r tlerating thers vilent, threatening r intimidating behavir.» Reprt instances f vilent, threatening and intimidating behavir, as well as any infrmatin that is reasnably perceived as indicating that such behavir is likely t ccur, accrding t CUNA Mutual Grup s Speak Up & Nn- Retaliatin Plicy linked in the related dcuments bx belw. * Please nte: If there is any cnflict between terms f this Crprate Plicy and a related Functinal Plicy, the terms in this Crprate Plicy will prevail. Vilatins f this plicy may result in discipline up t and including terminatin f emplyment. 1