Code of Ethics

The objective of this Code of Ethics and Professional Conduct is to define and explain to employees and the Company’s providers the legal and ethical requirements they must comply with in the exercise of their functions.

This document establishes the general principles and rules that must be followed by all of HDI Insurance’s employees, including members of the board of directors, suppliers, insurance and reinsurance agents, and by all of its workers while conducting business with HDI.

Suppliers whose work is made as representatives of the Company include, but are not limited to: technicians, arbitrators, claims regulators, attorneys, administrators and similar.

HDI Insurance’s suppliers, as well as their employees and business partners are obligated to follow this Code of Ethics and Professional Conduct when conducting business with the Company, especially when their professional activities are performed as representatives of the Company before third parties, particularly in any sphere of the Public Power.

Those who do not fulfill this obligation will be held accountable by any eventual penalties that may arise by any sphere of the Public Power, and will face contractual termination as well as any other legally applicable penalties.

The operating base for all of our employees and suppliers must be of a just and respectful conduct among themselves and with our clients and business partners, respecting the individual rights of each person. This also includes observing and abiding the contractually accepted obligations.

Unequal treatment on basis of ethnicity, race, gender, religion, ideology, incapacity, age or sexual identity will not be tolerated.

The relations in the workplace should be guided by courtesy and respect, and provide a healthy workplace. Team spirit, loyalty, trust, and a conduct compatible with HDI Insurance’s values and the search for results must prevail.

The use of post as means of asking for favors or personal services to subordinates is not permitted.

It is crucial to recognize the merit of each employee and grant equity of access to development opportunities according to the characteristics, skills and contributions.

No decisions that may affect a subordinate’s professional career or the commercial relationship with providers will be admitted based merely on personal relations.

HDI Insurance faces competition and fortification of our position in the market through the excellence of our services. Thus, employees must keep impeccable legal and ethical standards while searching to find their business objectives in a just and appropriate manner.

We only use licit means of obtaining information about our competitors and condemn all illegal activities that may generate complaints of responsibility.

Fair competition must be the base element in all operations and relations with other Companies in our market. Competitiveness must be practiced based on this principle.

Any action that may configure infraction of the economic order or impeachment of free competition, accordingly to the current legislation, especially the law number 12.529 from 11/30/2011, is prohibited. These include: limiting, falsifying or harming free competition or free initiative in any way; dominating a relevant market of goods or services; arbitrarily increasing profit; and assuming a dominating position abusively.

5.1 Confidentiality

Employees are obligated to keep silent about the Company’s confidential internal affairs, as well as about information from or related to our clients and business partners.

The Board Committee may authorize specific exceptions, in the usual business context or for specific cases (such as competitive processes).

Confidential information are all that are identified as such; or those which may be assumed to not be of public domain and which shall not be made public. Business, as well as commercial and industrial secrets, along with unpublished reports, including accounting, should be classified as confidential information.

Confidential information should be protected against non-authorized access by third parties. Confidential information within the Company must only be made available to employees who need them for their professional activities and may be subject to confidentiality regarding ethical denounces, objectivizing right preservation and decision impartiality.

The obligation of maintaining confidentiality and secret remains even after the termination of employment relationship.

5.2 Data protection

Employees and suppliers are obligated to respect the rules of data protection and to contribute actively so the data may be effectively protected against unauthorized access.

Data may only be archived, processed and used if this is required for definite processes in the performance of legitimate activities.

It is prohibited to, directly or indirectly, hide or dissimulate the nature, origin, localization, disposition, movement or property of goods, rights or values originated, directly or indirectly, from a penal infraction; as well as other crimes as define by laws number 9.613 from 1998 and 12.683 from 2012 (money laundering legistation).

Employees and suppliers must guarantee that HDI Insurance will not be used for money laundering or other illegal practices.

Employees and suppliers must guarantee that HDI Insurance will not be used for money laundering or other illegal practices.

All suspect cases must be communicated through our denunciation channels presented in item 13 of this Code.

HDI Insurance’s relationship with suppliers and authorities, politicians and civil servants must be based in ethical and professional attitudes. Bribery and corruption will not be tolerated and constitute penal infractions, both in relation to civil servants, and also to commercial matters.

It is prohibited to practice any crime described in the 2013 law 12.846, among them:

• Promising, offering or giving, directly or indirectly, an improper advantage to a public agent, or to a related third party;
• Financing, supporting, sponsoring or in any way subsiding the practice of illicit acts predicted in the referred Law;
• Using an interposed individual or company in order to hide or dissimulate your real interests or the identity of the beneficiaries of your actions;
• Frustrating, defrauding or committing any other crime described in the referred Law in relation to acquisitions and public acquisition contracts;
• Hampering investigative activities or supervision of organs, entities or public agents, or interfering in their activities, including within regulatory organs and supervising agencies from the national financial system;

Consultancy contracts outside of the usual business procedures, along with their payment, must be submitted to, and approved by, the Department of Compliance and Risk Management.

The contraction of policies with public companies, governmental organs and joint stock companies out of the terms of law 8.6666/93 is prohibited.

The highest standards of honesty and integrity must be observed in all contacts with administrators and partners of the public sector, always avoiding that the conduct may seem improper..

One should abstain from manifesting opinion regarding action or attitudes of public partners or comments of a political nature.

When defending HDI Insurance’s interests, one must act with confidence in the service standards of HDI Insurance and always observe the highest ethical principles and the respect current law and rules.

Privileged information are concrete, unpublished information about companies whose stocks, titles or other papers are negotiated in the stock market; which, if made public, may influence the price of those papers significantly.

Partners who are in possession of privileged information are prohibited of buying or selling stock, titles and other papers publicly negotiated by the Talanx Group Companies or by their business partners; of disclosing such information to third parties; or advising third parties to buy or sell such stocks, titles or other papers.

The disclosure of privileged information within the Talanx Group to other employees of the Company or Group is only permitted if they are absolutely necessary for the exercise of their duties. In case of suspicion of misuse of specific information that may be comprehended as privileged, regarding any of the Group’s Companies, the employee must communicate the Company through one of the denounciation channels presented in item 13 of this Code.

Employees that possess regular or occasional access to privileged information of one of the Companies of Talanx Group available in the stock market must be included in the list of people with privileged information in the respective Company.

The Talanx Group and its support education and the sciences, art and culture, as well as social causes or others recognized as worthy of support.

Donations to individuals, private accounts or receivers that may harm the prestige of the Talanx Group and its subsidiaries are prohibited. In case of sponsorship, one should guarantee that there won’t be disparity between the level of sponsorship and the economical objective.

Other payments or voluntary benefits without adequate accountability are prohibited.

The commitment with customer and insurance agent satisfaction must be reflected on the respect to their rights and the search for solutions that will attend to their needs, always according to the development objectives and the profitability of HDI Insurance.

Clients and agents must be treated in a courteous and efficient manner, offering clear, precise and transparent information. Both need to obtain answers, even if negative, to their requests, in an adequate way and in the expected time frame.

One should avoid giving special treatment to whoever, be it for interest or personal feelings.

Relationship with stockholders must be based on precise, transparent and opportune information communication that allows them to follow the activities and performance of HDI Insurance, as well as to search for results that bring positive impacts in the Company’s market value.

One must protect non-disclosed information that may affect or influence market movements and investment decisions.

The ethical problems, mostly, are not created by individuals, but rise up before them, forcing them to face them. The outlines of this Code allow to evaluate most of those situations, but do not give detailed descriptions, necessarily, to every problem that may arise in your day-to-day. Thus, eventually, there may be questions regarding the correct conduct for a particular situation. In those cases, one must look for help in a sincere and transparent manner.

One must communicate immediately and formally to a supervisor or local Area Director, whenever one is or seems to be in a situation that may characterize fraud, conflict of interests, or when one suspects or knows about facts that may harm the company or that contradict or seem to contradict the principles of this Code.

Other than questions regarding conducts that are not predicted in the Code, there may be incorrect actions of employees or administrators that may not have been included in the Code. If faced with this situation, the Committee of Ethics must evaluate and decide an applicable punishment.

It is also the Committee’s responsibility to take up the responsibility of judging cases of violations of the Code of Ethics and Professional Conduct of a greater severity and deliberate questions regarding text interpretation.

If you happen to know of a grave violation of the country’s laws or of this code’s rules, especially in case of fraud, embezzlement, corruption, cartel-building deals, falsification of balance sheets, or other actions that may characterize criminal or civil offense, or risk for the reputation of the Talanx Group, you can contact our Denunciation Line at 0800 770 47 17.

That information should give the Company and the Talanx Group the possibility of reacting on time to eventual anomalies to rectify them promptly. Communications may be realized anonymously or with indication of the denouncer, and will be treated with absolute confidentiality and the proper care.

If the suspicion is found to be unfounded, there will be no direct or indirect consequences related to it.