VI. Code of Conduct Does the company have an established Code of Conduct? If so, provide a copy and advise what the Code addresses and who receives it. Do you distribute the Code of Conduct and confirm that employees both receive and understand the Code and other policies? If so, please describe this process. Do you have a process for updating policies and procedures? Please describe this process. Can any requirements established by the Code of Conduct and other policies be waived or overridden? If so, please describe this process. Under the Code of Conduct, can employees, agents, and other stakeholders raise issues regarding compliance and ethics-related matters? If so, please describe this process. Does the Code have an established procedure to address compliance and ethics issues that arise? If so, please describe the procedures for this process and how the company scrutinizes the source of compliance failures? Does the Code provide guidance to take action against violators of the Code? If so, please describe how consistently this has been applied or whether other provisions are in place to address this issue. Is there a process for determining which issues are escalated to the board and for informing the board when issues are resolved? If so, please describe this process. Are there ongoing processes in place to monitor the effectiveness of the compliance and ethics program? If so, please describe. Does the organization engage an external law firm or consultant to audit compliance and ethics program elements? If so, please list the firm or consultant. Is the company a member of the Insurance Marketplace Standards Association and/or other best practices organizations? If so, please list.
VI. Code of Conduct Does the company have an established Code of Conduct? If so, provide a copy and advise what the Code addresses and who receives it. Do you distribute the Code of Conduct and confirm that employees both receive and understand the Code and other policies? If so, please describe this process. Do you have a process for updating policies and procedures? Please describe this process. Can any requirements established by the Code of Conduct and other policies be waived or overridden? If so, please describe this process. Under the Code of Conduct, can employees, agents, and other stakeholders raise issues regarding compliance and ethics-related matters? If so, please describe this process. Does the Code have an established procedure to address compliance and ethics issues that arise? If so, please describe the procedures for this process and how the company scrutinizes the source of compliance failures? Does the Code provide guidance to take action against violators of the Code? If so, please describe how consistently this has been applied or whether other provisions are in place to address this issue. Is there a process for determining which issues are escalated to the board and for informing the board when issues are resolved? If so, please describe this process. Are there ongoing processes in place to monitor the effectiveness of the compliance and ethics program? If so, please describe. Does the organization engage an external law firm or consultant to audit compliance and ethics program elements? If so, please list the firm or consultant. Is the company a member of the Insurance Marketplace Standards Association and/or other best practices organizations? If so, please list.