A message from David Harney, President and CEO, Great-West Lifeco Inc. and James P. O’Sullivan, Chair of the Board

Building trust and doing what’s right have always been core to who we are, and it matters now more than ever. As expectations of organizations continue to evolve, our Code of Conduct (the Code) helps ensure we make decisions that reflect our values and support our customers, colleagues, advisors/advisers, shareholders, and regulators.

Our Code is grounded in five core values that guide how we operate across our businesses and geographies:

• Acting with integrity
• Building trust and partnership
• Putting the customer first in all we do
• Fostering employee engagement
• Supporting stronger, more resilient communities

These values guide how we manage risk, protect information and assets entrusted to us, engage responsibly with others, and contribute positively in the communities where we do business. They also anchor our strategic imperatives – Customer first, always; a digital driven future leveraging data and AI; accelerating operational excellence; and being powered by talent – ensuring our strategy is executed responsibly and consistently and with care for the trust placed in us. Together, our values and strategic imperatives are fundamental to protecting our reputation and sustaining our long-term success. 

Living the Code is a shared responsibility and a reflection of our values in action. Each of us must understand and follow the Code, complete required training and Speak Up when something doesn’t seem right. Please know you can always raise concerns with your leader, Compliance, Human Resources, or through our confidential Ethics Hotline.

The Board of Directors joins us in endorsing this Code of Conduct and thanking you for the role you play in living our values and upholding our standards. Together, we can build on our strong history of doing what’s right and delivering on our promises to customers and stakeholders.