Code of Ethics and Standards of Practice of NAFA Premier Partner Members

Effective November 6, 2014

Where the words “NAFA Members” are used in this Code and Preamble, it shall be deemed to include Insurance Carriers, Broker Dealers, Banks, IMOs, NMOs, FMO General Agencies, Vendors and Consulting Firms. While the Code of Ethics establishes obligations that may be different than those mandated by law, in any instance where the Code of Ethics and the law conflict, the obligations of the law must take precedence.

Preamble

Premier Partners should recognize that the interests of the insurance marketing industry and its representatives require the highest and most ethical distribution insurance products. They require the creation of reasonable business practices, the marketing of sound financial products, and the ethical distribution of insurance products. Such interests impose obligations beyond those of ordinary commerce. They impose grave social responsibility and a patriotic duty to which Premier Partners should dedicate themselves, and for which they should be diligent in preparing themselves. Premier Partners, therefore, are zealous to maintain and improve the standards of their calling and share with their fellow Premier Partners a common responsibility for its integrity and honor. In recognition and appreciation of their obligations to clients, agents, representatives, the public, the carriers, the media, and each other, Premier Partners continuously strive to become and remain informed on issues affecting the insurance industry and, as knowledgeable professionals, they willingly share the fruit of their experience and study with others. They identify and take steps, through enforcement of this Code of Ethics and by assisting appropriate regulatory bodies, to eliminate practices which may damage the public or which might discredit or bring dishonor to the insurance marketing profession. Premier Partners must have direct personal knowledge of conduct that may violate the Code of Ethics.

Realizing that cooperation with other marketing professionals promotes the best interests of those who utilize their services. The acronym IMO connote competency, fairness, and high integrity resulting from adherence to a lofty ideal of moral conduct in business relations. In the interpretation of this obligation, Premier Partners can take no safer guide than that which has been handed down through the centuries, embodied in the Golden Rule:

“Whatsoever ye would that others should do to you, do ye even so to them.”

Accepting this standard as their own, Premier Partners pledge to observe its spirit in all of their activities whether conducted personally, through associates or others, or via technological means, and to conduct their business in accordance with the tenets set forth below.

Article 1

When representing a carrier or agent, advisor or broker, Premier Partners pledge themselves to protect and promote the interests of their representatives and their ultimate client, the consumer. This obligation to the client is primary, but it does not relieve Premier Partners of their obligation to treat all parties honestly.

The duties imposed by the Code of Ethics encompass all related activities. The duties the Code of Ethics imposes are applicable whether Premier Partners are acting as agents or in legally recognized non-agency capacities except that any duty imposed exclusively on agents by law or regulation shall not be imposed by this Code of Ethics on Premier Partners acting in non-agency capacities.

1. All Dealings

1.1 Engage in honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.

1.2 Maintain effective procedures to prevent confidential information being misused and make it clear that the use of confidential information for personal and corporate gain will not be tolerated.

1.3 Advance the legitimate interests of the NAFA Premier Partner community, having regard to our values and standards.

1.4 Comply with all applicable laws, rules and regulations in every state in which we operate.

1.5 Comply with anti-money laundering and counter-terrorist financing practice, law and legislation in all countries and territories in which we operate.

1.6 Forbid corruption and the paying or receipt of bribes.

2.  Dealings with Customers

2.1 Treat customers fairly, openly and honestly.

2.2 Provide high standards of service.

2.3 Operate effective complaints processes to deal with situations where these standards are challenged.

2.4 Aim to provide and promote a range of products and services that meet customer needs and are readily understandable.

2.5 Maintain the confidentiality of customer information, save where the law requires or permits disclosure, or the customer has given prior written consent.

3.  Dealings with Employees

3.1 Maintain a working environment that provides appropriate remuneration.

3.2 Maintain a working environment that provides training and opportunities for personal development.

3.3 Be intolerant of discrimination, harassment or victimization. Recognize diversity in recruitment and dealings with employees. Create a favorable employee relations environment in which the involvement of all employees is encouraged.

3.4 Support employees who become aware of and are willing to report business malpractice and have in place procedures to enable people who have a substantial reason to believe that malpractice is occurring, has occurred or is likely to occur within the business to raise issues internally without fear or recrimination.

3.5 Provide a clean, healthy and safe work environment, stressing the obligation on all employees to take every reasonable precaution to avoid injury to colleagues and members of the public.

3.6 Prohibit the illegal use of drugs on our premises and encourage any member of the staff with an alcohol or drug dependency to seek help.

3.7 Prohibit the use of forced or child labor.

4.  Dealings with Insurers

4.1 Maintain the highest possible standards of integrity in business relationships with insurers.

4.2 Encourage the use of those insurers who operate with values and standards equivalent to ours.

4.3 Work together with insurers to improve all aspects of performance.

5.  Dealings with communities

5.1 Contribute to the social and economic well being of those communities where we are an employer.

5.2 Encourage employees to participate in projects and initiatives to strengthen those communities.

5.3 Work to minimize adverse environmental impact of our business operations and to achieve group environmental policy targets.

5.4 Ensure that we conduct our activities, so far as possible, in a manner sensitive to the cultural and social traditions of communities with which we come into contact.

6.  Dealing with Competitors

6.1 Conduct business in accordance with our Code of Conduct and compete vigorously but honestly.

6.2 Avoid disclosing proprietary or confidential information in any contact with competitors.

7.  Dealing with governments and regulators

7.1 Maintain a constructive and open relationship with governments and regulators to foster mutual trust, respect and understanding.

8.  Compliance with this Code of Conduct

8.1 Businesses will explain to employees our values, the standards required under this Code and any associated responsibilities.

8.2 Businesses must be able to demonstrate that procedures are in place to ensure compliance with all requirements under this Code and periodic audit will be undertaken by internal audit.

8.3 Failure to comply with this Code may lead to the termination of NAFA membership and, where breaches of the law take place, may lead to criminal proceedings against the individual or individuals concerned

Explanatory Notes

The Code of Ethics was adopted in 2010 by membership vote at the 2010 Annual Convention.

The reader should be aware of the following by-laws and policies which have been approved by the Board of Directors of the National Association of Fixed Annuities.