Code of Conduct & Ethical Standards Policy

1. OBJECTIVE

This Code of Conduct & Ethical Standards Policy ("Policy") acknowledges that the organization is subject to certain federal consumer protection laws and regulations. The organization further acknowledges that, from time to time, it may generate interest in products and services offered in connection with consumer financial products and services. Guidance issued by federal consumer protection agencies requires, among other things, effective processes for managing risks. This Policy is published to reflect third-party risk management practices articulated in internal operations across all business units. This Policy is integrated as part of our compliance management program and daily operations. Adherence to this Policy applies broadly to all personnel.

1. SCOPE AND APPLICABILITY

   1. 2.1 This Policy applies to all employees, contractors, consultants, temporary workers, and other personnel acting on behalf of the organization.

   2. 2.2 The Chief Compliance Officer and Chief Legal Officer are responsible for ensuring this Policy and related policies are appropriately implemented and executed. This includes overseeing the development and implementation of an effective risk management and reporting framework that clearly addresses the elements outlined in this Policy.

2. COMPLIANCE WITH FEDERAL LAWS AND REGULATIONS

   1. 3.1 All personnel shall comply with all applicable federal laws and regulations, including but not limited to:

      • Health Insurance Portability and Accountability Act of 1996 (HIPAA)

      • Consumer Financial Protection Act

      • Federal consumer protection laws and regulations

      • Federal data privacy and security laws

   2. 3.2 The organization shall maintain written policies and procedures to detect violations of applicable laws that may arise in the performance of activities. Personnel must report any violation to the Chief Compliance Officer and take all steps necessary to prevent and resolve violations.

3. ETHICAL STANDARDS

   1. 4.1 All marketing materials must use plain, intelligible language, be factually accurate, and contain no potential misrepresentations.

   2. 4.2 Personnel shall ensure the security and confidentiality of the organization's confidential information and consumer information through appropriate information security measures.

   3. 4.3 Personnel shall maintain the highest standards of ethical conduct in all business relationships and activities, including but not limited to:

      • Acting with integrity, honesty, and transparency

      • Avoiding conflicts of interest

      • Protecting confidential information

      • Treating all individuals with respect and dignity

      • Promoting fair and non-discriminatory practices

4. DATA PRIVACY AND SECURITY

   1. 5.1 The organization shall comply with all applicable federal data privacy and security laws and regulations.

   2. 5.2 To ensure compliance with privacy laws, the organization shall:

      • Implement and maintain appropriate policies and procedures relating to data privacy and security

      • Make all required disclosures to governmental and regulatory authorities and individual data subjects

      • Take appropriate steps to ensure the proper collection, storage, use, processing, disclosure, and handling of personal data and confidential data

   3. 5.3 The organization shall promptly report any data breach or improper use, disclosure, or access to the appropriate authorities as required by applicable laws.

5. ENFORCEMENT AND DISCIPLINARY ACTIONS

   1. 6.1 Violations of this Policy may result in disciplinary action, up to and including termination of employment or business relationship.

   2. 6.2 The organization reserves the right to report violations of federal laws to appropriate law enforcement authorities.