Vendor Code of Conduct

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INTRODUCTION

At Reinsurance Group of America, Incorporated and each of its affiliated entities (RGA), we are stewards of a purpose-driven industry that helps people manage through the financial consequences of an uncertain future. Reinsurance is a unique business in which our product is a promise, and our ability to consistently deliver on our pledges builds the lasting trust that drives our success. RGA recognizes that vendor relationships play a role in our ability to build and retain that trust. As a result, we expect all new and existing vendors to place a high value on relationship focus, collaboration, integrity, and entrepreneurship – RGA's four core values. We expect all new and existing vendors to meet the expectations set forth in this Vendor Code of Conduct (Code), aspire to continuously improve upon existing processes, and innovate new processes. Vendors may be asked to provide written attestation that they have reviewed and agreed to abide by this Code.

 

RGA fosters a culture where people are accepted and embraced for who they are. This diversity of people brings diversity of ideas and more creative solutions, leading to better products and better results for our clients and the people they serve. Similarly, we expect vendors to encourage diversity in their workforce and embrace the value created by engaging a range of perspectives. 

Moreover, we expect our vendors around the world to protect all human rights. RGA's Human Rights Policy is guided by the United Nations’ Universal Declaration of Human Rights, the International Labor Organization’s Core Conventions, and U.S. law. We expect our vendors to fully comply with all applicable slavery, forced labor, and human trafficking laws; adopt an approach to human rights consistent with the United Nations Universal Declaration of Human Rights and U.K./AUS Modern Slavery Act; and comply with applicable laws regulating the minimum legal age to work. We expect our vendors to provide their employees with a process through which workers can raise workplace concerns without fear of retaliation for good-faith reporting. 

RGA is a values-based company. Our values guide our behavior at every level and apply across the Company on a global basis. We believe that sound principles of corporate governance are a key element of our business. Likewise, we expect our vendors to demonstrate the highest ethical standards while providing quality, innovative, and cost-effective services. 

Vendors are expected to comply with applicable regulations. All business dealings of our vendors shall be performed in accordance with applicable laws, such as anti-corruption laws, insider trading, intellectual property, as well as software licensing obligations, trademarks, and copyrights. RGA does not tolerate bribery or corruption involving its people, vendors, agents, or other business partners. Vendors are prohibited from corruptly offering, providing, paying, authorizing, promising, soliciting, or receiving anything of value, directly or indirectly, for the purpose of obtaining or retaining business or any improper business advantage.

As a publicly traded company, RGA is subject to regulations [dictating/outlining/limiting] what information is to be published about the Company. Our vendors should refer all requests for information about RGA directly to RGA. Vendors may not issue any public statements or disclosures about their relationship with RGA.  In addition, RGA does not allow its name, brand, or logo to be used on third-party websites or in third-parties advertisements, promotional or marketing materials, testimonials, or press releases unless expressly agreed to in writing by RGA.

 

RGA's reputation is fundamental to our ability to attract and retain clients. When partnering with vendors, we rely on these partnerships to help preserve this reputation. We expect our vendors to adhere to the highest ethical standards and have capabilities to support operational resilience. Appropriate controls related to outsourced arrangements are maintained through a structured due diligence process. Prior to executing a contract with a vendor, we conduct detailed assessments and due diligence activities commensurate with the level of risk presented by the vendor relationship. After RGA engages with a vendor, that vendor may be subject to periodic reassessment, on-site risk assessments, and/or other ongoing monitoring activities. We expect vendors to partner with RGA in good faith in the performance of relevant risk management activities. 

RGA is committed to protecting the personal information of customers and employees. Vendors are expected to comply with privacy and information security laws, regulatory requirements, and contractual obligations relating to the collection, storage, processing, access, transfer, and sharing of personal information. Additionally, Vendors are expected to comply with RGA’s Data & Analytics Ethics guiding principles

Protecting individuals' privacy is very important to RGA. Vendors are required to notify RGA if there has been an information security incident that has exposed or has the potential to expose RGA data to unauthorized parties. 

RGA is committed to the health and safety of our employees. RGA expects vendors to provide their employees with a safe workplace and follow all applicable laws relating to health and safety in the workplace. We expect vendors to have reasonable processes in place to detect, prevent, and address potential risks to the health, safety, and security of their employees.

At RGA, we embrace our responsibility to support sustainable, environmentally friendly business practices and to invest responsibly. RGA has a long legacy of environmental programs and initiatives ranging from energy efficiency measures to employee green committees. RGA considers the potential effects of climate change in its Own Risk and Solvency Assessment (ORSA) and enterprise risk management processes. These processes inform our business strategy. We evaluate and incorporate environmental, social, and governance (ESG) criteria when making investment decisions. 

RGA has pledged to achieve net-zero greenhouse gas (GHG) emissions throughout our global operations by the end of 2026. This past year, we took our first steps toward this goal by measuring our GHG emissions in alignment with the World Resources Institute’s Greenhouse Gas Protocol. We expect our vendors to follow all applicable environmental laws. We encourage our vendors to acknowledge and measure their impact on the environment and to strive to minimize adverse impacts.

Success in the financial services industry is dependent upon a company's reputation for integrity. RGA has a “Speak Up” hotline website, which is managed externally,  to allow external parties to report issues that are inconsistent with applicable laws and regulations, RGA's Code of Conduct, or any of RGA's policies and procedures. We expect our vendors to place primary importance on complying with all laws, regulations, and company policies pertaining to the identification and reporting of actual or suspected issues and to make a similar service available to their employees. If a vendor employee experiences or raises an issue in their work with RGA, we ask that the issue be reported to both the vendor and RGA.

 

RGA and its philanthropic arm, the RGA Foundation, focus on charitable giving and employee volunteerism. Our vendors are strongly encouraged to support and contribute to the betterment of the communities in which they operate and serve.

 

A reputation for integrity is vital to success in the financial services industry. Such a reputation, which takes years to establish, must be earned. RGA has earned such a reputation because of strong governance, effective management systems, and robust controls; each of which is core to how we operate. RGA values our vendor relationships and the mutual commitment to conduct business reliably and honestly without exception. This mutual commitment to responsible business practices is key to retaining the reputation for integrity. 

For additional information regarding these expectations and requirements, please email us at rgaprocurement@rgare.com.

Last Updated: October 2023