KEEPING PROMISE - Knights Of Columbus

thePROMISE Robert Benson PhotographyKEEPINGKnights of Columbus

K E E P I N G theP RO M I S ETo YouaNdOu r Orde r

Message from Supreme KnightCarl A. AndersonWhen Venerable Father Michael J. McGivneygathered a group of men in the basementof St. Mary’s Church in New Haven in 1882, hecouldn’t have imagined that the Knights ofColumbus would grow into an organization ofnearly 2 million men and one of America’s mostsuccessful insurance providers.With that growth has come change, butthe values that form our foundation – charity,unity and fraternity – have remained constant. Oursuccess, as a fraternal order and an insuranceprovider, would not have been possible if not forthe Knights of Columbus’ enduring commitmentto integrity, professionalism, excellence and respect.Consistently upholding these tenets hasearned us a designation as a World’s Most EthicalCompany by the Ethisphere Institute. Weshould all be proud of this because we share theresponsibility for making it so. As employees,each of us serves as an ambassador of our Order.Our behavior contributes not only to ourorganization’s reputation but also to a culture inwhich we can expect to be treated fairly, ethicallyand respectfully.In an effort to guide you and all the Order’scolleagues in upholding these standards, we haveupdated our Code of Ethics and Conduct (“TheCode”) for reference and use. I ask you to reviewand become familiar with this code, which appliesequally to all of us, regardless of title or position.Carl A. Anderson, Supreme KnightAt times, you may encounter issues relating toethical conduct, moral integrity or fair treatment.The Code can help you reach a solution. Whenissues arise, you should also reach out to yourmanager, supervisor or the Human Resources orLegal departments. All employees should feelconfident that they can report questionable orunethical activity without fear of discriminationor retaliation.The goal of our Code of Ethics and Conduct issimple: Regardless of the situation, we shouldalways strive to do the right thing. Our legacy ofintegrity can only remain as strong as those whocarry it.I thank each of you for your continuingdedication to the values that exemplify themission of the Knights of Columbus.

Knights of ColumbusFounding Principles and Core ValuesFather Michael J. McGivney founded the Knights of Columbus on the principles of Charity, Unity,Fraternity, and Patriotism. Today, these principles serve as the foundation of our Core Values:Integrity: Firm adherence to ethics, honesty, and a moral code.Professionalism: Promoting the highest standards in all we do.Excellence: Leading by example and constantly striving to be the best.Respect: Treating each other with the highest regard. Robert Benson PhotographyThis Code of Ethics and Conduct demonstrates how our Core Values guide us in situations that we may encounter.ii

CONTENTSKnowing the Role of Our Code .1KEEPING THE PROMISE MEANS .2Following Our Code and the Law .2Following Corporate and Business Unit Policies .2Respecting Our Duties .2Our role: How we all comply with our Code .2Responsibilities for Management.2KEEPING THE PROMISE TO THE ORDER .4Finding Help and Reporting Matters of Concern.4Explanation of Reporting .4Contacts for Reporting .4Making the Right Choice .4All Reports Will Be Investigated.5Complete Reports and Follow-Up Information .5Responding to Code Violations in a Fair and Consistent Manner.5Avoiding Conflicts of Interest.5Working With Family and Friends.5Financial Interest in Other Businesses .6Outside Employment.6Corporate Opportunities.6Gifts and Entertainment.6Ensuring Ethical Record Keeping .7Record Retention .7Communicating With Regulators, Attorneys and Investigators .8Responding to Media Inquiries .8Protecting the Order’s Assets .9Physical Property and Facilities.9Confidential and Proprietary Information .9Intellectual Property .9Using the Order’s Systems Properly .10

CONTENTSAppropriate Use.10Reputation at Risk .10Internet and Email Use .10Participating in Social Media .11KEEPING THE PROMISE TO EACH OTHER AND OUR PARTNERS .12Prevent Insider Trading .12Safeguarding Information .12Maintaining Safe Workplaces .13Health and Safety Concerns .13Substance Abuse .13Violence and Disruptive Behavior.13Preventing Harassment and Discrimination .13Practicing Corporate Ethics.14KEEPING THE PROMISE TO OUR MEMBERS AND COMMUNITIES.15Respecting the Environment .15Understanding Anti-Corruption .15Relationships with Public Officials .15Facilitating Payments.15Preventing Fraud.15Money Laundering.16Ensuring Service Quality .16Engaging in Ethical Sales and Marketing .16Following Competition Laws .17Prohibited Agreements with Competitors .17Handling Competitive Information.17Abiding by Trade Controls .17Boycotts and Restricted Countries/Sanctions .18Participating in Community Interests .18Political Activities .18

Knowing the Roleof Our CodeOur Code of Ethics and Conduct (Code) reflects our Core Values and explains howthey guide all Knights of Columbus (Order) activities and business operations.Situations involving ethics can be complicated, and sometimes it is difficult to knowwhat to do. Our Code is a resource to help us make sound decisions, even in complexsituations. It provides guidance on when and how to speak up if we have questions orconcerns. Consulting the Code should always be the first step in deciding how to handlean ethical dilemma or difficult decision. See “Finding Help and Reporting Matters ofConcern” (page 4) for more details.If you have any questions regarding any part of this Code, please contact yourmanager, Human Resources, or the Chief Compliance Officer.This document will be reviewed and updated every three years.QaWhat if I am facing a situation that is not covered in the Code?Our Code of Ethics and Conduct cannot address all of the issues that may ariseat work. If you are ever unsure of the right course of action, check our policies.If the answer is still unclear, it is always appropriate, in any situation, to ask forhelp. Start with your manager or any of the resources identified in the Code.An ethical workplace is not just an idea that we promote to the world; it is at the core of what westand for as an organization. Make sure your actions always reflect our Core Values.1Question or Concern? You may contact the Chief Compliance Officer at extension 4122, call theEthics Helpline at 855-806-7346, or visit https://reportlineweb.com/kofc to make a report.

KEEPING THE PROMISEMEANS. .Following Our Code andthe Law e Code and all related Order policies(policies) apply to all personnel of the Order.Examples of personnel may include, but are not limitedto, the following: Members of the Board of Directors (directors)Supreme Officers (officers)EmployeesInterns and StudentsAgentsContractors of the Order, its subsidiaries,and affiliatesAdditionally, our business partners, consultants,vendors, and suppliers must be familiar with ourCode and conduct themselves according to similarprinciples.Following Corporate and BusinessUnit PoliciesCorporate policies deal with specific topicsrelated to ethical conduct in the workplace that youshould know and follow. ese policies are locatedon the Order’s intranet site in the Corporate PolicyCenter. Along with knowing this Code, be mindfulof the laws, rules, and regulations that govern ourwork for the Order. Personnel should note thatindividual business units (departments) might issuepolicies and procedures relating to appropriatebusiness conduct. We must follow these rules inaddition to our Code’s guidelines.2We are all equally accountable for breaches ofthis Code or other policies. All of us must strive todo the right thing in all of the Order’s activities andbusiness dealings.Respecting Our DutiesOur role: How we all complywith our CodeAll personnel, no matter what their role, are expected to: Uphold our Core Values by always acting withIntegrity. Always be honest and ethical ineverything you do on behalf of the Order. Maintain the highest standards ofProfessionalism. Consistently strive for Excellence in our sharedmission. Complete all required ethics andcompliance training in a timely manner andapply it to your job every day. Treat others with the utmost Respect. Report concerns about possible violations oflaws, regulations, our Code and corporatepolicies. Cooperate fully and tell the whole truth whenresponding to an investigation or audit. Be accountable for your actions. Violating ourCode is grounds for corrective action, up to andincluding termination.Responsibilities for ManagementManagers, supervisors, officers, and directors(“Managers”) are expected to perform their jobswith professionalism and integrity.Question or Concern? You may contact the Chief Compliance Officer at extension 4122, call theEthics Helpline at 855-806-7346, or visit https://reportlineweb.com/kofc to make a report.

If a manager becomes aware of suspected or actual misconduct, includingviolations of the Code, he or she must report those concerns to the ChiefCompliance Officer or to Human Resources. Managers must make certainevery issue, concern, or question identified gets reported and resolved.Managers must ensure that there is never any retaliation against an employeefor fulfilling his or her responsibility under the Code by reporting in goodfaith.Managers are further required to: Understand, uphold, and communicate the concepts and values containedin this Code and related policies Be a role model. Lead with integrity and promote a culture of ethics andrespect. Make sure all business records are accurate and well-maintained Foster a safe, healthy working environment where all employees receive fairand respectful treatment Support your team and help them understand what is expected of them. Keep an open-door setting that encourages questions, feedback, andreporting Understand your obligation to report behavior thatviolates the Code, our policies or the law Utilize the resources listed in the “Finding Help and Reporting Matters ofConcern” section Never put business results ahead of ethical conduct or compliance with theCode or the law.Ultimately, managers are responsible for ensuring that personnel understandand comply with our Code, our policies, and any applicable laws orregulations. Additional reference material for responding to challenging ethicalsituations is available to managers in e Manager’s Playbook, which is availableon iLink.If approached with a question or concern related to the Code, managersshould listen carefully and give their complete attention. Ask for clarificationand additional information. Managers should answer any questions they are ableto, but are not obligated to give an immediate response.Question or Concern? You may contact the Chief Compliance Officer at extension 4122, call theEthics Helpline at 855-806-7346, or visit https://reportlineweb.com/kofc to make a report.3