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CODE OF BUSINESS CONDUCT

INTRODUCTION

The Code of Business Conduct describes expected business conduct grounded in our belief that trust and integrity are the foundation of our business.

Economical is committed to the highest level of legal and ethical standards in business conduct. Economical must be known as a company that deals equitably with its brokers, policyholders, employees and members of the public. The Code and the resources referenced in this document provide guidance on expectations of acceptable business conduct at Economical.

OVERVIEW

Application and scope

The Code applies to all employees of Economical, including regular full-time and part-time employees, contract employees, summer and co-op student employees, casual employees, and individual external contractors, as well as the officers and directors of Economical (which term also includes Economical’s controlled and wholly-owned subsidiaries). The Code’s standards of integrity also apply to Economical’s stakeholders, including customers, brokers, mutual policyholders, regulators, and communities, as well as contractors, subcontractors, and suppliers in relation to their business dealings with or on behalf of Economical.

Economical relies on employees to use their judgment to maintain high standards. Economical and its employees must follow the terms and spirit of The Code under all circumstances.

Roles and responsibilities

The corporate governance committee of the board of directors of Economical Mutual Insurance Company is the owner of The Code and is responsible for reviewing it every year. The corporate governance committee and management are responsible for ensuring that The Code is implemented effectively. The audit committee of the board of directors of Economical Mutual Insurance Company is the owner of the ethics reporting program and is responsible for reviewing it at least every two years.

Directors, officers, employees, and covered contractors, subcontractors and suppliers of Economical are responsible for communicating any identified whistleblower incidents in relation to Economical via the ethics reporting program as soon as they become aware of such situations.

Disclosure of conflicts

Employees must review The Code of Business Conduct annually. If a conflict of interest is disclosed,  leaders will provide employees with direction regarding the conflict. Employees are also required to disclose, throughout the year, any known or potential conflicts with The Code that may arise.

Contractors, subcontractors and/or suppliers of Economical are required to abide by the applicable terms and conditions of The Code to the extent included in their contracts and letters of agreement. They are not required to complete disclosure forms.

ETHICS REPORTING PROGRAM

Purpose

The purpose of Economical’s ethics reporting program is to establish procedures for the receipt, retention and treatment of complaints regarding wrongdoing, questionable accounting, internal controls, disclosure controls or auditing matters, contraventions of the integrity provisions of The Code, workplace safety, environmental issues and human resources issues; and the confidential submission by employees of concerns regarding such stated matters.

Breach of The Code

Bona fide breaches of The Code will be dealt with promptly after an investigation has been undertaken. In the event that, after an investigation, it has been determined that a breach of The Code has occurred, a decision will be made as to the appropriate corrective and/or disciplinary action that will be taken. Such action may include a warning or letter of reprimand, demotion, loss of salary increase or bonus, suspension without pay, termination of employment for cause and/or civil or criminal prosecution. In the case of contractors, subcontractors and suppliers doing business with or on behalf of Economical, breaches may be addressed through caution letters, cessation of business relationships and/or other appropriate means as circumstances may warrant.

What is a whistleblower incident?

A whistleblower incident is a good-faith concern related to wrongdoing, questionable accounting, internal controls, disclosure controls or auditing matters, contraventions of the integrity provisions of The Code, workplace health and safety, and human resources matters occurring at Economical. For guidance on corporate expectations around acceptable employee conduct, employees should refer to Economical’s other appropriate policies and procedures and the Human Resources department.

Whistleblower incidents include violations of the integrity provisions of The Code, Economical’s corporate policies, as well as the following areas of specific concern:

“Wrongdoing,” which includes the following examples:

  • Financial fraud
  • Embezzlement of company assets by an individual or group of individuals
  • Accepting “kickbacks” or conferring benefits
  • Violation of laws and regulations by individuals
  • Deliberately conducting business in direct violation of legal or regulatory requirements by which Economical is bound
  • Workplace health and safety violations
  • Endangerment of public health or safety
  • Sexual harassment or discrimination
  • Falsification of records, contracts and/or reports
  • Inappropriate retrieval, storage or use of customer or third-party information collected by Economical
  • Unethical behaviour or practices
  • Breach of fiduciary duty

Whistleblower incidents relate to matters regarding wrongdoing, questionable accounting, internal controls, disclosure controls or auditing matters as well as contraventions of the integrity provisions of The Code.

“Questionable accounting, controls or auditing matters,” which include the following examples:

  • Unethical or improper recording of financial transactions contrary to the generally accepted accounting principles applicable to Economical
  • Unethical, incomplete or improper disclosure of financial information
  • Misrepresentation of non-financial information to support the financial statements
  • Fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement, record, or report of Economical
  • Intentional circumvention of Economical’s internal controls over financial reporting or its disclosure controls and procedures

Whistleblower incident reporting

Economical has partnered with ClearView Strategic Partners Inc., a communications consulting firm that specializes in hosting confidential reporting systems. They have a proven track record of integrity, discretion and respect.

Employees can submit reports using ClearView’s web-based system or hotline and get step-by-step instructions to make reporting easy. ClearView is available to take reports 24 hours a day, seven days a week, and employees can rely on them to treat their report respectfully and confidentially. For employees to have the ability to follow up on a report that is submitted, they must submit it using either the web-based system or by speaking with a ClearView hotline agent. Either way, they will be given a secure login and password that they can use to check the status of their report.

Generally, employees should report concerns or complaints through existing channels, starting with their leader or department manager. The ethics reporting program should be used only where no reporting channels exist or where these existing reporting channels are not appropriate, or they feel uncomfortable using them. If reporting on something they have heard, but have not witnessed personally, they must indicate this in their report.

Reports regarding any wrongdoing by anyone, or any other breach of The Code by a member of senior management or the board of directors will automatically be sent to the chair of the board of directors. Reports regarding questionable accounting, controls or auditing matters will automatically be sent to the chair of the audit committee of the board of directors. Reports regarding any other unacceptable conduct or breach of corporate policies will automatically be sent to the Senior Vice-President and Chief Human Resources Officer.

In conducting an investigation, Economical will use reasonable best efforts to protect the confidentiality and anonymity of complainants, subject to the need to conduct a thorough investigation. As it may be necessary to identify the complainant, or it may be possible for third parties to deduce the complainant’s identity, anonymity cannot be guaranteed throughout an investigation.

The ethics reporting program is intended to encourage and enable employees, directors and officers to raise serious concerns within Economical, rather than seeking resolution outside Economical. Accordingly, it is the policy of Economical that it will not permit retaliation or harassment of any kind against individuals for complaints submitted under the ethics reporting program in good faith. Whistleblowers will not be discharged, demoted, suspended, threatened, harassed or otherwise adversely treated strictly as a result of reporting a whistleblower incident in good faith — whether that reporting is to a leader, to the Human Resources or Legal department, to ClearView, or to a law enforcement agency or regulator. The same is true of anyone participating in the investigation of a report.

A “good faith” report means that the reporter’s intentions are honest, and there is a reasonable basis for making the report. It does not matter if the specific circumstances reported actually amount to misconduct. However, making knowingly false or dishonest reports is a violation of The Code, and could be subject to disciplinary action, up to and including termination.

BEHAVING ETHICALLY

Economical Insurance is committed to the highest level of legal and ethical standards in business conduct. The company must be known as one that deals ethically with its brokers, policyholders, employees, and members of the public.

Economical and its employees consistently match words and actions — they do what they say they will do and lead by example. They exercise discretion in the use of information and respect confidentiality.

Economical and its employees always endeavour to deal fairly and equitably with policyholders and claimants, as well as with people making claims on policyholders.

A reputation for integrity is something that builds over time and earns us the confidence of our customers. In our commitment to integrity, Economical and its employees act responsibly, ethically, and professionally.

Deterring fraud

Fraud is any dishonest act or omission intended to deprive or mislead others for personal or corporate gain. Fraud includes criminal deception, the use of false representations to gain unjust advantage and dishonest schemes or tricks. Examples of fraud include misappropriating customers’ funds, submitting dishonest claims, and identity theft.

Our stakeholders expect Economical and its employees to conduct ourselves honestly and fairly. Employees should not participate in any type of dishonest or fraudulent behaviour that may affect Economical, our customers, partners, or co-workers.

Rejecting corruption and bribery

No funds or assets of Economical shall be paid, loaned or otherwise disbursed as bribes, “kickbacks”, or other payments designed to influence or compromise the conduct of the recipient. Economical and its employees shall not accept any funds or other assets for assisting in doing business with Economical.

Canada has specific anti-corruption legislation that prohibits companies from giving or offering anything of value to a government representative to influence a decision or assist that company in doing business. Other than for legally prescribed fees and similar payments, employees should obtain advance approval from their leader before they give any business-related gift to a government representative.

Avoiding conflict of interest

Employees of Economical cannot use their positions in Economical to gain — either directly or indirectly — a personal benefit for themselves or anyone else. Furthermore, they cannot use, for their benefit, confidential information gained through corporate business.

Some examples of conflict of interest include, but are not limited to:

  • Using corporate programs but not for the intended purpose; for example, submitting a receipt to one’s personal wellness account for someone not covered by that benefit plan
  • Using company email to conduct personal business such as selling goods online
  • Passing materials developed at Economical to third parties

Economical employees must avoid situations in which personal interests conflict, may conflict or might appear to conflict with their duties to Economical or where it may interfere with the ability of other employees to perform their duties. That includes but is not limited to:

  • Actions that will deprive Economical employees of the time or attention required to do their jobs properly
  • Directing other employees to undertake actions which could affect their ability to act in the best interests of Economical
  • Any business, financial or other relationship with suppliers, customers, competitors or Economical itself that may impair or even appear to impair the independence of Economical
  • Situations where there appears to be a conflict of interest, even if there is not actual conflict. The appearance of such a conflict is damaging because it can undermine trust among employees and costs Economical the respect of our customers.

All leaders must ensure that any actions taken or decisions made under their supervision do not give rise to a situation of a conflict of interest. Those who approve expenses, handle claims, handle assets, or who have access to confidential information, must ensure that decisions or actions do not create a situation which gives rise to a conflict of interest.

Economical does not tolerate fraud, corruption, bribery or conflict of interest or other unethical behaviour. Employees can help to ensure that Economical continues to operate ethically by reporting any suspected incidents, whether committed by a co-worker or a third party, to their leader, Human Resources, or through the ethics reporting program.

Managing salvage

After a claim has been settled, Economical may retain some recovered items, or salvage. No person may use or dispose of a salvaged item, except as described below.

Once salvaged items have been properly recorded, Economical may post an invitation for sealed bids from employees. Management, or an appointed employee, will open the bids at a specific time and place. Economical will then sell the salvaged items to the successful bidders, according to the stated terms and conditions of the salvage policy and process.

Economical employees are expressly forbidden from obtaining a personal benefit from the salvage process, for example, by influencing the bid or receiving a financial gain from the salvage process.

Reporting gifts and favours

Employees of Economical cannot accept gifts, valuable services, opportunities, favours, or privileges, for personal gain or pleasure, from anyone doing or discussing business with Economical. The same rule applies to immediate members of employee families.

This prohibition does not include normal business practices, such as business meals or entertainment, receptions, mementos, or inexpensive gifts. However, Economical employees are required to disclose participation in such events, or the offer of a gift, to their immediate leader at the time it occurs. In the case of officers, this is to be reported to the president and CEO. Economical absolutely forbids employees from accepting anything that could be interpreted as a bribe to sway business or be regarded as a payoff or secret reward.

In the event there is an industry function Economical has chosen to sponsor, management will assume the responsibility of selecting the staff to attend the event and the nature of the sponsorship of the event.

If employees have any doubts about a particular situation, they should avoid it. If they find themselves in a potentially compromising situation, they should report it immediately to their leader so that Economical can deal with the person or company who is trying to bribe or otherwise influence them.

Using company assets and funds

Economical’s assets include cash and other financial assets, as well as other items such as Economical’s name and all of Economical’s individual company names, information and data held or sent on company computers, supplies, equipment, telephones, computer resources, company cars and company credit cards.

Employees must comply with Economical’s policies and safeguard all Economical assets from loss, theft, carelessness, misuse or waste.

As part of the annual Code of Business Conduct process, employees are required to review and understand the Economical Expense Reimbursement Policy and Sourcing & Vendor Management Policy, and ensure their actions align with both policies.

Economical’s assets are to be used only for business of Economical. They are not to be used for personal purposes or in support of non-Economical business or activity.

COMPLYING WITH LAWS, REGULATIONS AND POLICIES

Each member company of Economical, and all individuals acting on its behalf, must obey the laws and regulations governing its businesses, as well as the policies and guidelines established by Economical. The insurance industry is subject to complex and changing laws and regulations. Such laws may vary among the provinces in which Economical does business. In order to avoid inadvertent and unintentional breaches, employees should seek clarification with their leaders about the application or meaning of any legal requirement.

This also includes Economical’s information security policies and the guiding principles for the conduct of Economical and its employees as articulated further in The Code. Included in this provision is compliance with all computer software copyright laws and corporate procedures relating to the use of software and equipment. The following sections discuss these compliance requirements in greater detail.

Complying with antitrust and competition laws

Economical employees must avoid all actions that reasonably could be construed as being anti-competitive, monopolistic, or otherwise contrary to laws governing competitive practices in the marketplace. The federal government has enacted “antitrust” or “competition” laws designed to ensure that markets for goods and services operate competitively and efficiently. The goal of these laws is to ensure that customers enjoy the benefit of open competition among Economical’s suppliers, and that sellers similarly benefit from competition among its purchasers. Violations of these laws can lead to substantial civil and criminal liability for Economical and its employees.

Most competition law regimes generally prohibit agreement or even communications among competitors on any aspect of competitive parameters (e.g., price, product or service).

For instance, when business competitors (actual or potential) agree (even if only tacitly) on the prices that they will charge our customers or prevent or impede other businesses from competing in a market, they may be committing an offence under competition laws.

Some examples of anti-competitive actions include, but are not limited to:

  • Communicating with or sending messages to competitors through any means about future pricing or other competitive activities
  • Exchanging information with competitors that may lead to price fixing

It is Economical’s policy to fully comply with all applicable competition and antitrust laws governing competitive practices in the marketplace.

Complying with anti-money laundering and anti-terrorist financing laws

Money laundering is the act of turning “dirty money” into “clean money” through a series of financial transactions so that the criminal origin of the funds becomes difficult to trace. Terrorist financing focuses on the destination and use of funds that may come from legitimate or criminal sources.  All employees must actively protect Economical’s products and services from being used for money laundering or for financing terrorist or other criminal activity.

Some examples of money laundering behaviours include, but are not limited to:

  • Suspicious premium payments
  • Irregular patterns or anomalies in financial transactions

Detecting money laundering and terrorist financing activity requires us to properly identify and authenticate our customers. Employees must report any suspicious activities to their leader. If they fail to do so, Economical may be exposed to the risk of legal sanction, financial penalties and reputational damage.

Complying with information disclosure obligations

Economical is or will be required under securities laws to provide the public with timely and periodic disclosure regarding Economical’s business and financial condition (such as quarterly and annual reports and materials for our annual general meeting). Economical provides additional disclosures to the public through quarterly press releases and may provide additional disclosures through analyst conference calls and other press releases and filings, as events warrant. All of those who participate in the preparation or dissemination of these disclosures, or who provide information that they know may be used in the preparation of these disclosures, have a legal and ethical duty to ensure that the disclosure is full, fair, accurate, timely and understandable. In addition, all employees are subject to the Public Disclosure Policy.

Economical maintains disclosure controls and procedures designed to meet these disclosure obligations. If employees become aware that a public disclosure is not accurate, complete or timely or of a development that they believe may require disclosure, they should report the matter immediately.

Each member company of Economical, and all people acting on its behalf, must obey the laws and regulations governing its businesses, as well as the policies and guidelines established by Economical.

CONDUCTING OURSELVES WITH REGULATORS, AUDITORS, AND OTHERS

The reputation of Economical and its employees is built on our daily interaction with our stakeholders and the public. Employees can all build Economical’s value by meeting the highest standards of professional conduct. Specifically, Economical and its employees co-operate with lawful investigations and inquiries by or on behalf of Economical, regulators, law enforcement agencies, external and internal auditors, and other investigators. Economical and its employees provide accurate and factual information to them, and do not mislead or attempt to improperly influence them. Economical and its employees do not tamper with any document to obscure the true nature of a transaction in Economical’s records or to impede or influence an audit, regulatory review or investigation. Such action may include a warning or letter of reprimand, demotion, loss of salary increase or bonus, suspension without pay, termination of employment for cause, and/or civil or criminal prosecution.

UPHOLDING DIVERSITY

Economical is committed to achieving a fair and equitable work environment. The recruitment and selection process represents the first crucial step in the employment relationship. Economical will base hiring decisions on each individual’s qualifications, regardless of race, colour, national or ethnic origin, sex, gender identity or expression, sexual orientation, disability, age, family or marital status, or any other factor unrelated to job performance.

Avoiding harassment and discrimination

Human Rights legislation guarantees that every person has the right to be treated equally on the job or while applying for a job. This means everyone should be evaluated on their own merits and treated with respect. A primary concern of Economical is to ensure the dignity, respect, and personal safety of all employees. It is the responsibility of Economical to provide a workplace that is free of harassment, including for reasons based on race, colour, place of origin, ethnic origin, religion, gender identity or expression, sexual orientation, sex, age, conviction of offence that has been pardoned, marital status, family status, genetic characteristics, or disability.

Economical and its employees, officers, and directors have a responsibility to conduct themselves in a manner that does not at any time constitute harassment in any form. Further, Economical and its employees, as well as officers and directors of Economical, have an additional responsibility to report behaviour that may constitute harassment and to support any appropriate remediation thereof.

MAINTAINING INFORMATION SECURITY

At Economical, information needs to be protected throughout its lifecycle to maintain confidentiality and integrity. Information security refers to the protection of information from unauthorized access, use, disclosure, disruption, modification, or destruction. Information is used daily and can be spoken, printed, faxed, stored, or transmitted electronically.

All information needs to be protected; however, the level of protection depends on the value, sensitivity, and risk associated with the information.

Threats to information security can impact all forms of information and can come from inside an organization as well as from outside. For this reason, employees are expected to have an awareness of information classification (such as “public” or “business confidential”) as well as the handling and protection requirements for that information.

The Information Management Policy applies to all Economical employees with access to Economical information and to all information in all forms, including:

  • Paper-based documents
  • Electronic documents, electronic data record storage, data within applications, data in transit, audio/video recordings, electronic backups, internal/external storage
  • Electronic communications, including emails, text messages, social media postings

Information is classified by two criteria:

  1. By sensitivity to Economical as restricted, business confidential, or public
  2. By retention requirement as a permanent record, a business record or transitory information

The need for protection increases with the sensitivity of the information. Highly sensitive information is not only confidential, but access to this information needs to be restricted to those individuals and groups that “need to know.” Information of this nature should not be distributed to other employees or externally without permission of the information owner. Electronic copies should only be stored on company devices, not on personal devices (e.g., home computers, tablets, mobile devices), or publicly shared computers (e.g., hotel business centre, internet kiosks), nor should any information be stored on non-approved cloud services (e.g., Dropbox, Google Drive, iCloud). When it is necessary to share this information, handling policies should be followed and encrypted removable media should be used instead.

Economical and its employees have the responsibility to protect information by never downloading or using unapproved software and services; only using encrypted removable media; and protecting mobile devices (including laptops, tablets, phones) from being lost or stolen.

Intellectual Property

The intellectual property of Economical includes copyrights, inventions, computer software programs, processes, websites, applications, trade secrets, and trademarks. Any intellectual property arising from, or created during, the performance of duties as an Economical employee (inside and outside of regular business hours, at or away from an employee’s usual location) belongs exclusively to Economical and will remain with Economical after an employee leaves the employ of the organization.

Economical’s intellectual property is an asset of Economical and may only be used as permitted by The Code, and Economical policies and guidelines. It may not be used by others without permission. Similarly, Economical and its employees respect the intellectual property of others, and Economical employees may not use the intellectual property of others without their permission.

Safeguarding records and reporting

It is important to create, maintain and modify business records in accordance with Economical’s policies. Employees are responsible for the integrity of all financial records that they help create or maintain. To preserve Economical’s reputation as an organization characterized by its honest and forthright dealings, false or misleading information must never be included in any business records.

Examples of financial records include: auditor information, expense accounts, overtime sheets, business marketing plans or documents, claims reports, insurance premiums or policies, and all other business and financial documents that employees help to create or maintain.

All assets, debts and business of Economical must be accurately and promptly recorded. Economical and its employees cannot hold funds and must report all expenses properly. Complete, accurate and timely communications with the board of directors, corporate officers, internal and external auditors and all matters relevant to them are essential.

Confidential documents must be disposed of properly using secure shredding bins (not in regular trash or recycle boxes). Personal and private information must be handled appropriately. Employees must not provide information to anyone unless they know they are contracted business partners and it is appropriate for them to have the information.

Maintaining confidential information

During the course of their duties, employees will learn confidential information about Economical, other employees, suppliers, brokers or policyholders. Confidential information might include, but not be limited to, trade secrets, strategic information, product literature, new product development information, customer lists, financial documents, operational procedures, business plans, marketing plans and strategies, pricing, and personal information concerning employees (including personal information such as one’s own salary), policyholders and brokers of Economical. Economical and its employees are required to maintain all such information as confidential.

Employees of Economical cannot, under any circumstances, disclose to anyone confidential information concerning Economical, its businesses, its employees, policyholders, suppliers, or brokers, except as required by our employment with Economical. After leaving the employ of Economical, former employees are strictly forbidden from keeping, using, or disclosing any such confidential information, except for disclosure in good faith through our ethics reporting program or to law enforcement agencies or regulators in relation to perceived violations of applicable legislation. All records are the sole property of Economical and must not be removed from company premises, with the following exceptions:

  • During the normal course of business duty, employees may have business documents in their possession. They are responsible to keep these documents and the information therein confidential and secure.
  • Records placed in offsite storage in secure locations for archival or backup purposes.

Information handling guidelines are available with information security policies.

Passwords and access

Passwords and other access credentials are confidential.  An employee’s user ID and password are designed to uniquely identify them and to provide the appropriate level of authorized access to computer resources, business applications and company information. Employees must not share them with anyone or leave them unsecured.

Passwords should be mixed case, non-dictionary words, include numbers and symbols, or, a passphrase (e.g., Love2Golf4Fun) where possible so that the user can remember them without writing them down, but they are complex enough that they cannot be guessed. Passwords are easier to remember if they’re not changed on a Friday afternoon or before going on holidays. Employees should not re-use the same password or account for company systems and personal use.

Safeguarding privacy

As an insurer, Economical needs to collect, use, and disclose personal information. Personal information is any information about an identifiable individual but does not include the name, title, business address, or telephone number of an employee of an organization. Personal information will usually come directly from the individual or from his or her representative (e.g., insurance broker).

Economical and everyone acting on its behalf (including employees) must not collect, use, or disclose personal information except in accordance with Economical’s privacy statement which is available on our internal and corporate websites. In the event of a possible loss of, unauthorized access to, or unauthorized disclosure of personal information in Economical’s custody or control resulting from a breach or lack of security safeguards, employees must follow the Privacy Incident Protocol, which is available to all employees on Economical’s internal website.

In particular, the privacy statement provides that Economical, and all people acting on its behalf, will only collect, use and disclose personal information where the individual to whom the personal information pertains:

  • Has been informed of the specific purposes for which the information is to be collected, used and disclosed
  • Has consented to the collection, use and disclosure of the personal information for those purposes identified to him or her at or prior to the time of collection

In summary, Economical, and anyone acting on its behalf may not collect, use or disclose personal information for purposes other than those to which each individual has provided their consent.

USING EMAIL, INTERNET, TELEPHONE, AND COMPUTER RESOURCES

Use of Economical resources is governed by the Acceptable Use Policy. There should be no expectation of personal privacy while using Economical resources. Management has a right to access any information stored on or transmitted through Economical’s systems and/or through company-provided devices (including but not exclusive to laptops, desktops, tablets, and mobile devices.)

When there is a cause to believe that there have been violations of policies or security, email, internet usage, text messages, and/or instant messages may be monitored/reviewed. Examples of violations include safety violations, illegal activity, misuse of corporate resources, discrimination, and sexual harassment.

Use of email

Email content, including attachments, requires the same attention to information protection as paper documents and adherence to the Information Management Policy guidelines. Information related to privacy, financial information, or other business-confidential topic is sent only to those who are involved and have a “need to know.” Employees are advised to avoid using reply-all, and to be cautious with “auto-fill” email addresses and check for non-Economical recipients before sending email to verify if they should be included. Calendar details are marked private if they relate to confidential matters, especially if attachments are included, and company email or calendar details are not forwarded outside of the company.

Employees should be cautious before clicking on links and attachments, especially from unknown contacts.

Limited, occasional, or incidental use of email and instant messaging for personal, non-business purposes is understandable and acceptable. However, employees must demonstrate a sense of responsibility and may not abuse the privilege. Economical email addresses should never be used to sign up for any external personal services.

Unacceptable personal messages include:

  • Sending mail or messages that promote personal business
  • Sending material that is inappropriate (e.g., offensive, defamatory) and may reflect poorly on the organization or yourself
  • Sending mail or messages that are sexual in nature

Use of Internet

We all use the internet every day. Economical and its employees need to be aware of the risks associated with increased internet exposure. The threat landscape has changed dramatically over the years and internet connectivity raises the exposure of Economical information. The internet usage policy is designed to help employees understand Economical’s expectations for the use of the internet and to help protect its information and assets. This applies to everyone who performs their duties at Economical’s business sites, or from a remote location. Employees may not download/install any unapproved software from the internet. Employees are also not permitted to connect personal devices to the corporate network.

The Internet Usage Policy prohibits access to certain categories of sites, including:

  • Adult content, nudity and sex
  • Personals and dating
  • Hacking, countermeasures, and bypass methods
  • Gambling, audio/video downloads, or streaming media for non-business purposes
  • Racism, hate, religion, militancy, extremism, violence, and weapons

Use of telephone

Economical’s telephones are important tools for use in business operations. Economical and its employees are encouraged to conduct personal business on the telephone during lunch or other breaks. Personal calls are to be kept brief and to a minimum, except in emergency situations. Personal calls should be restricted to local calls, unless charged to the employee’s personal (home) number.

When using a mobile phone while travelling, a hands-free speaker device should be used by employees. Hand-held calls require that pulling off the road and bringing the automobile to a complete stop. Employees must always be aware of their surroundings when conducting business on a mobile device, to avoid unknowingly exposing company information to the public.

Use of computer workstations or tablets

Use of company assets, resources, and information for legitimate business should be done in accordance with the Acceptable Use Policy.

Software may not be downloaded or installed without being approved. This also applies to free or open source software. Workstations and mobile devices must be locked and any removable media devices secured. Only approved encrypted removable media devices may be used for company information.

Employees must use only approved business locations to store Economical information and according to the appropriate controls for the sensitivity of the information.

If any employee has a complaint about violations of the email and instant messaging policy, a written request should be sent to Human Resources to investigate the violation. Any disciplinary action will be determined by management in consultation with Human Resources.

Using social media

Social media forums such as Facebook, Twitter, LinkedIn, and blog platforms have changed the nature of communications with colleagues, customers, and the world at large. Economical expects everyone who chooses to participate in the various forms of social media to do so in a manner conforming to its guidelines and corporate policies. Posting opinions on blogs and other social media is acceptable as long as it conforms with Economical’s Social Media Guidelines and is done professionally, respectfully, and in good taste.

CONDUCTING OURSELVES WITH KEY STAKEHOLDERS

To customers, Economical employees represent Economical and so are expected to demonstrate the highest professional standards. Economical and its employees strive to understand the needs of each customer and to deliver the best solutions without fail.

Employees of Economical apply knowledge of the company’s internal practices, processes, systems, products, services, structure and relationships. They also apply their knowledge of the external environment within which they operate and interact. This includes knowledge of the financial services industry, the marketplace, customers, business partners, competitors and suppliers.

Economical and its employees use this knowledge and skill for the benefit of Economical’s key stakeholders by:

  • Providing superior customer experience and overall value proposition
  • Being a preferred business partner in its distribution channels
  • Demonstrating industry-leading skills in pricing, underwriting, claims and risk management
  • Being a great place to work
  • Maintaining the trust and confidence of all stakeholders

By outlining expectations and procedures with respect to Economical customers, The Code better equips Economical and its employees to provide exceptional services and, in that way, fosters an ease of doing business with Economical.

Employees, officers, and directors represent Economical and so are expected to demonstrate the highest professional standards to customers.

Demonstrating professional appearance and behaving courteously

In keeping with its high corporate standards for providing quality products and service, Economical employees are expected to maintain a professional, business-like appearance in both grooming and attire during business hours and outside of business hours at company or industry functions. A professional image reinforces Economical’s high-performance business culture.

First impressions of Economical’s workplace and its employees can have a significant impact on the success of Economical’s business. Economical’s professional image conveys its values, achievements and work ethic. First impressions are often lasting. Employees are expected to present a professional, business-like image to Economical’s business contacts and associates at all times.

Behaving respectfully

Employees of Economical influence others to achieve organizational goals. This includes relationship building, facilitation and negotiating skills. Economical employees retain composure when faced with difficult situations. They reflect the concerns of others, are easy to talk to, and maintain and build productive working relationships. Economical and its employees demonstrate respect and tolerance and balance the needs of people who have different views, perspectives, and backgrounds. Employees encourage and seek to learn from others’ perspectives and experience.

Working together

Economical and its employees work hard to make teamwork work. Building a culture that supports effective teamwork involves breaking down silos across traditional boundaries. This allows employees to gather and share information, plan approaches and make decisions together, incorporating varied perspectives. As a result, employees can respond more rapidly, better meet needs, use resources more efficiently, creatively solve problems, and share responsibility for successes and lessons learned. Teamwork also keeps the overall best interests of the company paramount.

Communicating with the media and public

Economical’s public and media relations team manages all public and media affairs to ensure professionalism and safeguarding of its reputation. If someone from the media asks employees about any aspect of Economical’s business or the industry in general, they should refrain from commenting, instead referring them to Economical’s Public and Media Relations team who are responsible for communicating Economical’s position to the media.

Further, only specifically authorized spokespersons can express Economical’s views on local and national issues that affect its operations, or on Economical’s financial results. No other person is authorized to speak on behalf of Economical. Authorized spokespersons are the president and CEO and other persons authorized in writing by the president and CEO.

Employees should take care not to make personal statements in public that could be interpreted as reflecting the “official” position of Economical.

If someone from the media asks an employee about any aspect of Economical’s business or the industry in general, the employee should refrain from commenting and instead refer them to our Public and Media Relations team.

ENABLING A HEALTHY ORGANIZATION

Economical is a socially responsible organization committed to creating and sustaining a supportive, safe and healthy workplace. Economical embraces principles that prevent occupational illness or injury and promote employee wellbeing through the provision of health and lifestyle resources.

Avoiding smoking

Economical’s working environment is smoke-free, which includes tobacco, cannabis, and vaping products (provided that tobacco products and non-cannabis e-cigarettes can be used only in designated smoking areas). This applies to all building facilities (owned or leased), and company-provided vehicles.

Avoiding alcohol and drugs

Illegal drugs are not permitted in the workplace, which includes off-site work events. Alcohol is not permitted on company property other than in the instance of planned/ controlled business social events for which proper permits have been obtained (e.g., a broker appreciation open house). Possession and use of cannabis for recreational purposes is not permitted in the workplace, including off-site work events. Possession and use of cannabis for medical purposes is permitted on company property, within the limitations established by Economical’s Smoking Policy and Medical Cannabis Policy.

Employees are not to report to work, or be at work, if they are impaired by alcohol or drugs (legal or illegal). Employees who fail to comply with the alcohol and drug policy will be subject to disciplinary action, up to and including termination of employment (subject to the duty to accommodate in the event of an established addiction-related disability).

PARTING THOUGHTS

The Code cannot possibly cover all aspects of ethical business conduct. Common sense and good judgment must be used to determine what constitutes acceptable behaviour.

Each year each employee is required to review The Code. Employees must also complete the related eLearning assessment with a 100% success rate.