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Ethical business conduct

Ethical business conduct

The Board has adopted a written Code of Business Conduct and Ethics (the “Code of Conduct”) 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 website or you can download a printable version.

The Board oversees compliance with the Code of Conduct through Great-West Lifeco’s Chief Compliance Officer who monitors compliance with the Code of Conduct and reports to the Audit Committee on such compliance at least annually. Officers and employees must report known and suspected breaches of the Code of Conduct to their local Compliance Officer or to the Chief Compliance Officer, and Directors must report known and suspected breaches to Great-West Lifeco’s senior legal officer or to the Chair of the Board. All reported breaches and results of investigations are reported to the Audit Committee by the Chief Compliance Officer.

All Directors, officers and employees of Great-West Lifeco (and of Great-West Lifeco’s subsidiaries) are required to confirm annually their understanding of, and agreement to comply with, the Code of Conduct (which contains standards of business conduct regarding conflicts of interest), and pursuant to the Code of Conduct 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 Great-West Lifeco’s senior legal officer or the Chair of the Board.