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Ethical business conduct

Ethical business conduct

The Board has adopted the Code of Conduct (the “Code”) that governs the conduct of Great-West Lifeco’s Directors, officers and employees. A copy of the Code of Conduct is available on the SEDAR websiteOpens a new website in a new window or you can download a printable versionOpens in a new window.

The Board oversees the Code through the Corporation’s Chief Compliance Officer who is responsible for monitoring compliance with the Code of Conduct and reporting to the Risk Committee on the state of ethical conduct in the organization. Officers and employees are encouraged to report known and suspected breaches of the Code, and Directors must report known or suspected breaches to the Corporation’s senior legal officer or to the Chair of the Board. Any reported breaches or results of investigations are reported to the Risk Committee by the Chief Compliance Officer.

All Directors, officers and employees are required to confirm annually that they have read, understood, complied with, and will continue to comply with the Code. Under the Code, all employees must disclose any actual or potential conflicts of interest to their local compliance officer or to the Chief Compliance Officer, and Directors must disclose any actual or potential conflicts to the Corporation’s senior legal officer or to the Chair of the Board.

To help ensure that Directors exercise independent judgment in considering transactions and agreements in respect of which a Director or an executive officer has a material interest, the Director or executive officer having a conflict of interest must declare his or her interest and abstain from voting on that particular matter.