BRANT MUTUAL INSURANCE COMPANY CODE OF BUSINESS PRACTICE FOR AGENTS PURPOSE Brant Mutual Insurance Company and its agents are committed to the highest level of personal and corporate standards in the conduct of insurance activities. This Code of Business Practice sets out minimum standards of business practices ensuring that agents of Brant Mutual Insurance Company continue to earn the trust and confidence of the company's policyholders and other stakeholders. SCOPE In their Contract/Agreement with Brant Insurance Company, Agents agree to abide by a number of ethical guidelines and to carry on business in a manner consistent with the highest standards of professional ethics. This Code, together with any codes of ethics issued by their provincial regulatory body, collectively reflects the high standards with which Agents of Brant Mutual Insurance Company must comply. This Code applies to agent's activities with respect to all products and services offered by Brant Mutual Insurance Company. Any breach is a breach of the agent's Contract/Agreement and gives the Company grounds to terminate the Contract/Agreement for cause. ANNUAL COMPLIANCE ACKNOWLEDGEMENT Each year, Agents of Brant Mutual Insurance Company 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 Representation The Agent's responsibility, authority, and relationship with Brant Mutual Insurance Company must be made clear to clients. Client Trust Agents must be committed to providing the highest quality of personal service that can reasonably be expected. Honesty, fairness and service are hallmarks of the way agents of Brant Mutual Insurance Company conduct business. Information provided by Agents must be clear, honest, relevant, factual and as complete as is practical. Agents must sell the insurance company's products and services on their merits, with a full description of the benefits and costs. Client Privacy To ensure the confidentiality and proper use of personal information relating to clients, agents must conduct business in accordance with the insurance company's privacy code and the Personal Information Protection and Electronic Documents Act (PIPEDA). RELATIONS WITH THE COMPANY Agents Authority Agents are authorized to solicit applications for such policies as the Company may issue. Agents have such other authority as is expressly given by Contracts/Agreements, but agents may not, on behalf of the Company, amend policies, waive policy provisions, or bind the Company by promise of agreement in any way. Agents are obligated to provide full disclosure of information to the Company regarding applications or claims. Conflict of Interest Situations should be avoided where Agents' personal interests conflict, or might appear to conflict, with their responsibility to policyholders or the Company. Agents' conduct must be able to bear public scrutiny. Any external personal or business interests that could compromise sound judgment or diminish agents' personal commitment to policyholders or the Company should be avoided. Agents must 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, personal benefit for themselves or for others. Agents must ensure that their actions or decisions are free from the influence of any interest which might reasonably be regarded as conflicting with that of Brant Mutual Insurance Company. Agents must make timely disclosure to the Manager or 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. 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 software. RELATIONS WITH REGULATORS Compliance with Laws and Regulations Agents must comply with both the letter and the spirit of all laws and regulations governing their business. They must make every effort to become familiar with insurance laws applicable to them. Agents under investigation by a regulator or professional organization must report forthwith that fact to the Manager or the President of the Board of Directors of the Company. Agents must not split commissions with or pay any other form of compensation to any other person for soliciting or placing any product offered by the agent, unless that person is properly licensed. Rebating Agents shall not, directly or indirectly, rebate or attempt to rebate all or any part of a premium.