Generali Group

Code of Conduct
2019

Approved by
the Board of Directors of

Assicurazioni Generali S.p.A.

01.
A message
from the
Group CEO

2
 A message
01. from the Code of Conduct
Group CEO

I am pleased to introduce to you Generali’s Code of Conduct.

This document, rather than a list of obligations, should be regarded as a recognition of our identity as a team
and of the values we all identify with. In addition, this document states our rights to be treated fairly and
without discrimination as well as to work towards the objectives of an organization that consistently promotes
and rewards work ethics and the best management practice in the interest of all its stakeholders.

Generali’s purpose is designed to guide human choices

well beyond the current strategic cycle and contingencies:

to enable people to shape a safer future

by caring for their lives and dreams.

Such noble purpose derives from, and contributes to shape, Generali’s culture. Generali’s purpose and
culture distinguish the great professionals who work for Generali and, as a result, the whole organization, its
value proposition, its market positioning and its brand. They are what allows Generali to gain the trust of its
customers to build life-time relationships with them. They represent what we – as co-workers and human
beings – decide to stand up for, defend and foster. They drive our actions, fuel our motivation and cement our
bonds, even beyond simple work interactions.

They also inspire habits, including visible behaviors to which we all commit. Behaviors such as showing human
touch and feeling true owners of activities and projects are particularly conducive to Generali’s purpose.

Lastly, Generali’s purpose and culture are reflected in a set of regulations, some of which are codified and laid
down in this document. I invite you to read the Code of Conduct, to adhere to its guidance, to use it as a
reference in case of doubt or if you deem inappropriate behaviors must be reported and to raise awareness
on its content and use it among your colleagues.

I am convinced that Generali’s Code of Conduct, as one of the foundations of the Group’s cultural identity,
serves as the ideal complement to the expertise, passion and talent of each of the company’s colleagues
in order to deliver long-term success and sustainability, to contribute positively to the well-being of all
stakeholders and, ultimately, to realize the purpose of enabling people to shape a safer future by caring for
their lives and dreams.

Yours,

Philippe Donnet
Group CEO

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 Table
of contents
01. A message from 2 Personal information and privacy 12
Conflicts of interest 12
the Group CEO
Anti-bribery and anti-corruption 13
02. Common provisions Customer relations 14
6
Fair competition and antitrust 15
Applicability 7 Supplier selection 15
Implementing regulations 7
Financial information 16
Duty to comply 7
Insider dealing 16
Reporting concerns and incorrect conducts 7
Communicating with certain external parties 17
Breaches 7
Anti-money laundering, anti-terrorist 18
03. Rules of conduct 8 financing and international sanctions

Fair conduct of business 9

Sustainability 9 04. Final provisions 19
Work environment, diversity and inclusion 9 Adoption and distribution 20
Workspace 11 Training 20
Assets and business data protection 11

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 Table
KEY Code of Conduct
of contents

Key (color code)

This document is subject to periodic changes and updates. Edits and additions applied to the current edition
are marked in the text with a specific color.

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02.
Common
Provisions

6
 Common Code of Conduct
02. provision

Applicability
This Code of Conduct (the “Code”) defines the fundamental rules for employees, including members of
supervisory and management bodies (collectively, the “Employees”) of the Generali Group.

Third parties (consultants, suppliers, agents, etc.) who act on behalf of the Group are expected to adhere to
the principles set out in the Code.

Implementing regulations
The Code is complemented by a set of implementing regulations.

While these regulations set minimum standards of behaviour, Group companies can adopt additional
measures.

Duty to comply
All Employees are responsible for knowing and observing this Code and the other internal regulations relevant
to their particular tasks and activities.

Employees must attend introductory and yearly refresher training programs.

Reporting concerns and incorrect conducts

The Group encourages Employees to report concerns on practices or actions they consider to be factually or
potentially in breach of law, the Code and the other internal regulations.

Reports can be made personally or anonymously, in writing or orally, and are treated with strict confidentiality
according to the law and the provisions of the relevant internal regulations.

Retaliations against Employees who report concerns in good faith are not tolerated.

Refer to “Reporting concerns and incorrect conducts” regulation

Remember
The behavior rules set out by the Code affect our daily work. For any new activity we
undertake, we should ask ourselves not only if it is legal and allowed by applicable regulations,
but also whether it aligns with the spirit of the Code and of the Internal Regulations.

Breaches of the Code endanger the business and reputation of the Group. So, do not
hesitate to speak up and report misconducts that you have witnessed.

Breaches
Breaches of the Code or of the implementing regulations by employees may result in disciplinary actions
according to local applicable regulations.

Breaches may also result in the award of damages or criminal prosecutions.

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03.
Rules
of conduct

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 Rules Code of Conduct
03. of conduct

Fair conduct of business

The Group conducts business in compliance with law, internal regulations and professional ethics.

Employees must behave fairly and honestly, observing applicable law, internal regulations, the provisions of
this Code and of the implementing regulations and the Group’s sustainability commitments. Managers are
expected to act as a role model and promote a culture of ethics and compliance.

Refer to “Group Compliance Policy”

Sustainability
The Group aims at contributing to economic and social development based on the respect for fundamental
human and labour rights and the protection of the environment. The Group promotes a culture of sustainability
throughout its spheres of influence, specifically among its employees, customers and suppliers.

Employees are therefore committed to:

making the most of their colleagues, promoting development and recognizing individual contributions
made to the success of the organization;

improving the circumstances of the communities where the Group operates, playing a role as a
corporate citizen in support of institutions, organizations and associations;

putting the skills and resources of the Group at the service of those who are most vulnerable, in order
to promote the integration of the poorest and most disadvantaged people;

considering also the environmental, social and corporate governance conduct of the counterparts,
when managing the Group’s underwriting, investments and purchasing activities;

contributing to protection of the environment, promoting a reduction in the direct and indirect
environmental impact of their activities.

In the Charter of Sustainability Commitments the Group sets out its sustainability model and defines its
priorities. Employees must act in accordance with the Group’s commitments and in order to achieve its
sustainability vision.

Refer to “Sustainability Group” regulation

Work environment, diversity and inclusion

The Group ensures a stimulating work environment, free of any kind of discrimination or harassment. Diversity
and inclusion in the workforce are promoted, in the belief that cooperation between people with different
cultures, skills, perspectives and experiences is fundamental in attracting talent and to enable business
growth and innovation.

Continues...

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 Rules Code of Conduct
03. of conduct

Employees shall treat one another with respect, avoiding conducts that may hurt someone else’s dignity.

Managers must create and promote a welcoming and supportive environment, where integrity, respect,
cooperation, diversity and inclusion are effectively pursued.

Decisions concerning Employees, including recruiting, hiring, training, evaluation and advancement, are based
exclusively on individual merit and performance and cannot be influenced, for example, by race, ethnicity,
religion/belief, sexual orientation, marital status or political view.

Communications towards Employees need to be open and fair. The Group encourages the development
of individual capabilities and skills by providing adequate professional training as part of a broader staff
development framework.

The Group recognises freedom of association and collective bargaining for its employees.

It strongly rejects any form of irregular work or exploitation as well as any kind of forced or compulsory labour
and child labour.

The Group stands against any kind of harassment, bullying and mobbing.

Refer to “Promoting diversity and inclusion” regulation

Remember
Anti-harassment warning signs and tips
We have to strongly reject any disrespectful behaviour, keeping in mind that harassment is
determined by how others perceive our actions, regardless of our original intentions.

Thus, for example, sexually oriented e-mails or text messages, unwelcome gestures or
physical contact, as well as offensive or degrading comments about personal characteristics
are prohibited and must be considered as forms of harassment, regardless of whether they
were intended as playful remarks or jokes.

If you feel that you are a victim of any sort of harassment,

bulling or mobbing:
write down what happened (date, time, place, situation, witnesses) and keep evidence
of any inappropriate conduct (e.g. materials, written conversations, etc);

make it clear to the harasser that such conduct is unacceptable and must stop, pointing
out that the Group firmly stands against any form of harassment and this misconduct is
severely sanctioned;

if the harasser does not stop his/her misconduct, do not hesitate to report the situation,
since it is a violation of this Code.

Remember that you can always ask your manager or Compliance Function for support.

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 Rules Code of Conduct
03. of conduct

Workspace
The Group ensures a healthy, safe and secure workspace.

The Group guarantees to its Employees fair working conditions, ensuring a safe and healthy environment.

Employees are requested to avoid conducts that may endanger anyone’s health or safety.

Employees support the Group’s endeavours to protect the environment and to minimize the environmental
impact of their working activities.

Assets and business data protection

Group tangible and intangible assets must be preserved.

The Group tangible assets, including real estate, equipment and supplies, must be protected from damage
and misuse and must be used for working purposes only, unless properly authorized.

Business-related information, including any acquired in the performance of assignments on behalf of the
Group, shall be treated as confidential. Employees must handle it with strict confidentiality and disclose it only
on a need-to-know basis or if specifically authorized. The same rules apply to all documents containing such
confidential information.

Group intellectual property (i.e. ideas, products, methodologies, strategies, etc.) must be protected, if
appropriate, also through patents, trademarks and copyrights.

The obligation to preserve the Group’s intellectual property continues even after the employment with the
Group ends.

All business data must be recorded accurately and completely. Records and documents must be available
and accessible at the request of authorities or authorized staff.

Records and data, including electronic files and e-mails, must be retained as long as required by the applicable
laws; in the event of pending or foreseeable litigation or authority inspections they must be retained for any
longer time necessary.

Fraudulently altering or falsifying any record or document is strictly forbidden.

Remember
Disclosing information on a need-to-know basis means that access to such information must
be allowed only for specified and legitimate purposes. Thus, whenever asked to disclose
confidential information, we have to carefully verify the purpose of the request, even if coming
from another department of the same company.

Business related information must be safeguarded through its entire life-cycle. We have to pay
attention to dispose of documents containing confidential information, since the same rules for
proper handling apply.

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 Rules Code of Conduct
03. of conduct

Personal information and privacy

Personal information must be properly handled and privacy rights must be respected.

Personal information concerning third parties, whether customers, employees, suppliers or others, must be
handled on a need-to-know basis and in accordance with local law.

Personal data must be collected, processed and shared only for specified, legitimate and required purposes
and to the extent they are strictly necessary.

Privacy options and preferences stated by the owner of any personal information must be respected.

Particular care is needed in transferring data across national borders, including between Group companies.
In general, before transmitting information, Employees are required to verify which restrictions, if any, are
provided for by law, consulting with Compliance Function whenever in doubt.

Refer to “Group Personal Data Protection” regulation

Remember
Personal information is information relating to an identified or identifiable individual, e.g. health
and family matters, passport or identity card number, banking information etc.

Conflicts of interest
Employees must act pursuing the Group’s interests.

A conflict of interest occurs when an Employee is involved in personal activities or relationships that might
interfere with his/her ability to act in the best interest of the Group. In general, conflicts of interests should be
avoided and, if a conflict is unavoidable, it must be managed in order to avoid detriments to the Group.

Employees are expected to be aware of potential conflicts that can arise in daily business activities and must
report these to their manager or the Compliance Function. If they have any doubt in relation to the existence
of a conflict of interest, they shall seek clarifications from their managers or the Compliance Function.

Refer to “Conflicts of interest” regulation

Continues...

12
 Rules Code of Conduct
03. of conduct

Remember
Conflicts of interest arise when we, our family members or other close persons, could receive
personal gains as a result of our position in the Group or through access to confidential
information, as well as when one of our relatives is hired due to our influence or our position in
the company.

Furthermore, conflicts of interest could depend on doing activities outside of the Group, for
example serving as an employee, director or consultant of companies, foundations or non-profit
organizations, when such activities are remunerated by entities that have or expect to enter in a
relationship with the Group.

Anti-bribery and anti-corruption

The Group condemns and combats all forms of bribery and corruption.

Employees must conduct business in an honest and ethical way.

Any form of corruption, including bribery and extortion, is not tolerated. Thus, Employees must abstain from
offering or accepting undue payments, gifts, entertainment or other benefits.

It is always forbidden to promise, give or receive gifts in the form of cash or equivalent payment methods, or
any other kind of negotiable securities.

Gifts, entertainment or other benefits may only be offered or accepted in connection with business activity and
if deemed commonplace and appropriate to the circumstance (i.e. when they are reasonable and comply with
local laws) and should not normally exceed € 100.

The nature of the Group business requires interaction with public officials, public institutions or authorities,
representatives of political parties and trade unions. In such circumstances Employees must refrain from
offering or receiving, directly or indirectly, anything unless in connection with ordinary business activities and
in line with law and common local practices. Any gifts and invitations for entertainment events made to public
officials require the approval of the Compliance Officer.

Employees must inform their direct manager and the Compliance Function about any attempt to give or to
receive undue gifts, entertainment or other benefits that could create the appearance of improper influence
in business decisions.

Refer to “Anti-bribery and anti-corruption” regulation

Continues...

13
 Rules Code of Conduct
03. of conduct

Remember
Gifts are inappropriate if they do create an appearance of bad faith or improper influence in
business decisions.

The same rules apply for gifts, entertainment or other benefits that are given to your family
members.

Customer relations
Customer satisfaction is a key factor of the Group’s business strategic view, enabling the Group to strengthen
and improve its leadership position.

In relations with customers, Employees are required to behave correctly and honestly, forthrightly and
professionally, and to refrain from deceptive or misleading practices.

Employees must always consider the customers’ best interests, providing solutions appropriate to their
needs. Conflicts of interest shall be avoided or, if unavoidable, be managed in order to protect the interests
of customers.

In proposing products and services, Employees must only make statements that are factual, truthful and
completely accurate.

After-sale assistance must be granted and easily accessible.

Customer satisfaction must be constantly monitored. New products and services must be developed in line
with customers’ evolving needs and identified areas of improvement.

The products and services development process must be clearly defined, and a strategic plan of new products
and services must be periodically adopted by each Group Company.

Remember
When proposing products and services to our customers, we are expected to act in their best
interest, hence informing them of all relevant aspects of the product or service being offered.

We must furthermore ensure that consumers are appropriately informed before, during and after
sale, and that they are enabled to freely submit a claim or make a complaint.

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 Rules Code of Conduct
03. of conduct

Fair competition and antitrust

The Group recognizes the fundamental role of free competition in increasing business opportunities and
performance.

Competition must be based on superior products and services and on fair commercial practices.

Employees are forbidden to discredit competitors or their products or services or to manipulate, conceal or
present a distorted view of reality in order to obtain illicit gains.

Furthermore, practices and conducts aimed at restricting free and fair competition are prohibited.

Employees need to be mindful of applicable competition laws and anti-trust regulations when dealing with
competitors in order to avoid improper conducts.

To this end, the Legal and Compliance Functions shall be consulted for clarifications on local law and
regulations.

Refer to “Group Competition” regulation

Remember
We must consider as anti-competitive practices the following:

all agreements with competitors aimed to fix prices or premiums or to restrict the kind or
quantity of products or services being offered;

all agreements with suppliers or agents aimed to restrict free competition;

the exchange of information with competitors about future strategies related to products or
prices.

Supplier selection
The Group ensures fairness, transparency and straightforwardness in the relationships with its suppliers.

In the relations with suppliers, Employees are required to behave fairly, transparently and straightforwardly and
to avoid situations of conflicts of interest.

The selection of suppliers must be exclusively based on principles of fair competition and on the quality of the
products and services offered.

The quality of products and services must be assessed against international ethical criteria regarding labour
and human rights and in consideration of the environmental impact of production and supply methods.

Refer to “Ethical Code for suppliers of the Generali Group”

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 Rules Code of Conduct
03. of conduct

Financial information
Complete and accurate financial information is a fundamental means of enabling stakeholders to make
informed decisions in their relations with the Group.

Financial reports must be truthful, fair, complete and in strict compliance with the Group and local accounting
standards.

Employees must deal with financial data honestly and accurately, maintaining detailed and undistorted financial
information in a recoverable format for the duration of the assigned retention period. Fraudulent alterations or
falsifications of records or documents are forbidden and can never be justified.

Managers are expected to promote a culture of internal control over financial reporting.

Financial statements and other information addressed to shareholders, regulators and the public must be
understandable and publicly available according to the applicable local law.

Remember
Business goals and objectives must be reached fairly and without fraudulent alteration or
falsification of any kind.

Do not hesitate to report conducts which appear to conflict with this statement.

Insider dealing
The Group takes measures to prevent the improper use of inside information and ensures the fair management
of deals involving securities.

Inside information is specific information that is not in the public domain but, if made public, could significantly
influence the price of securities.

Such information, regardless of whether it is related to a company of the Group or to another company
outside the Group or their listed securities, must be treated with strict confidentiality and disclosed on a need-
to-know basis according to the provisions of local law.

When in possession of inside information, Employees must refrain from disclosing it, except to their colleagues
who have a valid business reason to receive it. Inside information may also be disclosed to third parties
(lawyers, auditors, consultants, etc.) who have a need to know it in connection with a proper reason and have
executed appropriate confidentiality agreements.

Continues...

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 Rules Code of Conduct
03. of conduct

Employees in possession of inside information are prohibited to deal, directly or indirectly, or to provide tips
or make recommendations about Group securities or other securities, if transactions are based on such
information. Same rules apply regardless of whether they deal in securities for personal purposes or in the
behalf of the Group.

In any case, Employees who are planning to deal or to recommend someone to deal in Group securities must
fully comply with the applicable laws and Group or local policies.

Remember
Inside information may concern, for example:

performance results, especially if they are unexpected;

unannounced imminent introduction of an important new product or service;

executive management changes;

changes in the strategic direction;

changes in capital structure;

mergers, acquisitions or sales of any material asset or company of the Group.

Documents related to meetings of supervisory and management bodies, as well as all

documents related to senior management decisions, often contain inside information. Such
documents must therefore be retained no longer than strictly necessary and handled in the
strictest confidence.

Communicating with certain external parties

The Group supports the transparency of financial markets, ensuring a careful management of communications
with the media, financial analysts and the public.

All communications towards the Group’s stakeholders must be forthright, timely and accurate.

Relations with the media, financial analysts, rating agencies, investors and authorities are exclusively managed
by specifically designated functions.

Employees must refrain from giving information about the Group, or documents containing any, to such
parties unless authorized.

Employees are requested to abstain from publicly commenting on rumours about the Group, if not confirmed
by official sources.

Continues...

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 Rules Code of Conduct
03. of conduct

Remember
Posting information on social networks, such as LinkedIn®, Facebook®, Twitter® etc. means
spreading data to a wide audience of people. Thus, we must be very careful in disclosing
information about the Group when using social media sites.

Anti-money laundering, anti-terrorist financing and

international sanctions
The Group is committed to the international fight against money laundering and the financing of terrorism,
to complying with the sanctions laws and regulations and opposing any conduct that could be intended as
supportive of these financial crimes.

Relevant Employees must obtain and maintain a suitable knowledge of customers and of the sources of funds
made available for transactions subject to Group policies or legislation.

Every time Employees suspect that the counterparty is attempting to use the Group’s products or services for
illegal purposes, such as money laundering or terrorist financing, they must promptly inform their Compliance
or Money Laundering Reporting Officer.

Relevant Employees must have a full and updated knowledge about relevant restrictive measures adopted
by the European Union, the United Nations, the United States and local applicable jurisdiction against certain
countries, people, assets or services.

Refer to “Group Anti-money laundering &

Counter-Terrorism Financing” and “Group
International Sanction” regulations

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04.
Final
provisions

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 Final Code of Conduct
04. provisions

Adoption and distribution

The Code has been approved by the Board of Directors of Assicurazioni Generali S.p.A.

The Code is adopted by the administrative, management or supervisory body of each Group company.

CEOs are responsible for overseeing the implementation of the Code and of the implementing regulations in
accordance with local legal requirements.

The Code replaces any other existing code of conduct within the Group. All internal policies must comply with
the provisions of the Code.

Should conflicts arise between the Code or the implementing regulations and the local legislation, these shall
be promptly reported to Group Compliance to ensure a successful resolution.

Group Compliance is responsible for proposing to the Board reviews of the Code in order to keep it current.

To ensure that it is easily accessible and publicly available, the Code is translated into all the languages of the
countries where the Group operates and published on the Group’s corporate website – www.generali.com –
and on the websites of each company of the Group.

Training
In order to guarantee that the Code and the implementing regulations are properly understood and effectively
enforced, introductory and annual refresher compliance training programs must be arranged.

CEOs encourage a widespread awareness of the Code and the implementing regulations and ensure the
involvement of all Employees in compliance training programs.

CEOs ensure that each Employee is provided with a copy of the Code.

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Generali Group
Code of Conduct
2019

Approved by
the Board of Directors of

Assicurazioni Generali S.p.A.