BRANT MUTUAL INSURANCE COMPANY CODE OF BUSINESS CONDUCT PURPOSE Brant Mutual Insurance Company is committed to the highest level of personal and corporate ethical standards in the conduct of its business. This Code of Business Practice sets out minimum standards of business practices that Brant Mutual Insurance Company expects of each employee and directors to continue to earn the trust and confidence of its policyholders and other stakeholders. SCOPE This Code of Business Conduct applies to employees and directors of Brant Mutual Insurance Company. Strict adherence to the provisions of this Code is mandatory and full compliance is expected under all circumstances. Any breach will be cause for remedial action, which could include termination of employment. Anyone aware of a contravention of this Code is invited to report the matter immediately to either the Manager, or to the President of the Board of Directors, of Brant Mutual Insurance Company. ANNUAL COMPLIANCE ACKNOWLEDGEMENT Each year, employees and directors are asked to reaffirm their commitment to comply with the Code, and to provide assurance that they have complied with it over the last year. RELATIONS WITH CLIENTS Client Privacy To ensure the confidentiality and proper use of personal information relating to its clients, employees, agents and directors, the Company will conduct its business in accordance with its own privacy code as well as in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA). Client Trust The Company is committed to providing the highest quality of personal service that can reasonably be expected. Honesty, fairness and service are hallmarks of the way Brant Mutual Insurance Company conducts business. Information provided to all with whom the Company does business must be clear, honest, relevant, factual and as complete as is practical. Products are sold on their merits, with a full description of the benefits and costs. Misrepresentation of the Company's or a competitor's products and services is prohibited. RELATIONS WITH THE COMPANY Company Assets The assets of Brant Mutual Insurance Company consist of property and information to which the Company is legally entitled. The assets of Brant Mutual Insurance Company are not to be used in any way for personal gain. This applies not only to funds, facilities, equipment and supplies, but also to such properties as client data and information technology. Conflict of Interest Situations should be avoided where the personal interests of employees or directors conflict, or might appear to conflict, with their responsibility to Policyholders or to the Company. The conduct of employees and directors must be able to bear public scrutiny. Any external personal or business interests that could compromise sound judgment or diminish an individual's commitment to the Company must be avoided. Employees and directors should not use their position in the Company or confidential information acquired in connection with the business of the Company to gain, either directly or indirectly, a personal benefit for themselves or for others. Employees and directors should ensure that their actions or decisions are free from the influence of any interest which might reasonably be regarded as conflicting with that of the Company. Employees and directors should make timely disclosure to the Manager or to the President of the Board of directors, in writing, of all personal business, commercial or financial interests or activities where such interests or activities might create, or appear to create, a conflict of interest. RELATIONS WITH REGULATORS Compliance with Laws and Regulations Brant Mutual Insurance Company, and all persons acting on behalf of the Company, must comply with both the letter and the spirit of all laws and regulations governing its business. They must make every effort to become familiar with the law as it pertains to the business carried out by the Company. Human Rights Brant Mutual Insurance Company supports and conducts its business in accordance with human rights legislation. Brant Mutual Insurance Company hires and promotes people on the basis of their individual abilities and compensates them on the basis of performance. Discrimination or harassment in the workplace with respect to such matters as race, colour, sex, sexual orientation, citizenship, age or handicap is strictly forbidden.