I. OVERVIEW

Acrisure, LLC, together with its Platforms, Agency Partners, subsidiaries and controlled affiliates (collectively, “Acrisure”), is committed to conducting business in accordance with the highest industry standards and in full compliance with all applicable laws and regulations. Accordingly, Acrisure expects all companies and individuals with whom Acrisure does business, including, but not limited to suppliers, vendors, subcontractors, and any other third parties acting on Acrisure’s behalf (individually, a “Supplier,” and collectively, “Suppliers”) and persons acting on Suppliers’ behalf (including subcontractors and employees) (collectively, “Supplier Parties”) to act in accordance with such industry standards and applicable laws and regulations and to meet the minimum standards included in this U.S. Supplier Code of Conduct (this “Code”). Supplier is responsible for compliance with the standards set out in this Code throughout its operations and by all of its suppliers, vendors, agents, and Supplier Parties.

The most recent version of the Code can be found at:

Acrisure.com/suppliercodeofconduct. Any questions regarding this Code should be directed to the Supplier’s Acrisure relationship contact. All reporting or notices required hereunder must be made to Acrisure’s Chief Legal Officer at [email protected]. 

 

II. SCOPE & APPLICABILITY

This Code applies to all Suppliers with whom Acrisure does business in the U.S. and is in addition to, and not in lieu of, the contractual commitments included in any agreement(s) by and between Acrisure and Suppliers. To the extent more stringent terms or requirements are contained in an agreement by and between Acrisure and a Supplier or in any applicable laws and regulations, the more stringent terms or requirements govern and control. By continuing to do business with Acrisure, Suppliers agree to comply with and be bound by this Code. 

 

III. SUPPLIER STANDARDS

A. Legal and Regulatory Compliance 

Acrisure expects all Suppliers to conduct business in full compliance with all applicable laws and regulations. Acrisure has zero tolerance for unlawful or unethical conduct in any form. Where this Code requires Supplier to meet a higher standard than set out by law or regulation, Supplier shall meet the higher standard.

As a regulated entity in the insurance and financial services industries, Acrisure may be subject to specific regulatory requirements. Therefore, Suppliers and their subcontractors shall cooperate with all government-sponsored regulatory requests and inquires related to the goods or services that are provided to Acrisure. 

1. Anti-Corruption Compliance

• Suppliers must comply with all applicable local or global laws and regulations relating to the prevention of bribery and corruption, including the U.S. Foreign Corrupt Practices Act.
• Suppliers must never give bribes or kickbacks, regardless of custom or practice. Suppliers must not offer, promise, provide or authorize the payment of money or anything of value--including but not limited to cash, cash equivalents (such as gift cards), loans, job opportunities, gifts, meals, entertainment, hospitality, travel, charitable or political donations, and sponsorships--to any person, company or government official, whether directly or indirectly through a third party, to improperly influence that person, company or government official to get any business or professional advantage, including obtaining or retaining business, directing business to anyone or securing any other improper advantage or give the appearance of impropriety. ¹ Facilitation payments are strictly prohibited.

2. Anti-Money Laundering Compliance

• Suppliers must comply with all applicable U.S. and non-U.S. laws and regulations pertaining to the detection, prevention and reporting of money laundering and the financing of terrorism.

3. Sanctions Compliance

• Suppliers must comply with all applicable sanctions laws and regulations and, without limitation of the foregoing, must not conduct any Acrisure-related business with persons subject to applicable sanctions.
• Suppliers must not conduct any Acrisure-related business with any person on any of the following sanctions lists: the List of Specially Designated Nationals and Blocked Persons maintained by the U.S. Department of the Treasury's Office of Foreign Assets Control, the United Nations Security Council Consolidated List, the UK Sanctions List and the Office of Financial Sanctions Implementation Consolidated List of Financial Sanctions Targets in the UK, and the Consolidated List of Persons, Groups, and Entities Subject to EU Financial Sanctions.
• Suppliers must not conduct any Acrisure-related business, directly or indirectly, with or in relation to Cuba, Iran, North Korea, Syria, the Crimea, so-called Donetsk People's Republic, or so-called Luhansk People's Republic regions of Ukraine, or the non-government controlled areas of the Kherson or Zaporizhzhia oblasts of Ukraine.
• Suppliers must immediately notify Acrisure of any possible violations of applicable sanctions laws or regulations that relate, directly or indirectly, to the Supplier's business with Acrisure.

4. Political Activity

• Suppliers must comply with all applicable laws and regulations relating to the political activities and other interactions between the Supplier and any public officials.

5. Fair Competition

• Suppliers must conduct their business in accordance with all applicable anti- trust laws and fair competition laws and regulations.
• Suppliers must compete lawfully in all markets in which they operate and must never discuss with any competitor prices, bids, customer sales, bid rigging, market allocation or other competitively sensitive information.

6. Whistleblowing

Supplier or Supplier Parties must notify Acrisure as soon as practicable if there is a reasonable belief that any of the following misconduct may take place, or has already taken place, by an "associated person" of Acrisure

• A criminal offense (e.g., bribery, tax evasion, money laundering, sanctions breaches, anti-competitive conduct, and fraud);
• A failure to comply with a legal obligation;
• A danger to the health and safety of an individual;
• A breach of environmental protection laws;
• Inappropriate relationships with suppliers (e.g., conflicts of interest);
• False accounting or financial reporting irregularities (e.g., embezzlement or misuse of corporate funds);
• A breach of Acrisure's rules or policies (including this Code); or
• A deliberate concealment of any of the above matters.

As used herein, an "associated person" of an entity includes, but is not limited to, current and former employees, directors and officers, agents and others who act on such entity's behalf (e.g., contractors, subcontractors, consultants, freelance workers).

Any information received will be treated seriously and, as far as possible, confidentially. If the alleged misconduct by the associated person falls outside the categories detailed above but relates to Acrisure's operations, a Supplier Party should notify Acrisure as soon as reasonably practicable.

7. Insider Trading

• Suppliers must comply with all applicable rules and regulations regarding insider trading.
• Suppliers may not purchase or sell securities of Acrisure or any other entity (including entities unaffiliated with Acrisure) while in possession of material nonpublic information about Acrisure or that other entity obtained in the course of doing business with Acrisure.
• Suppliers may not provide material nonpublic information to another who may trade or advise another to trade on the basis of such information obtained in the course of doing business with Acrisure.

8. Privacy, Confidentiality and Data Security

• Acrisure expects its Suppliers and Supplier Parties to be committed to protecting the confidential information of every entity with which the Supplier does business, including Acrisure, its customers, and its employees.
• In order to protect the information and data of Acrisure and its clients, Supplier and Supplier Parties shall comply with all applicable privacy and data security laws and regulations and utilize industry and market standard best practices to protect any and all such information and data when Supplier stores, shares, processes, or transmits information and data within its possession, custody or control.

B. Compliance with Code

All Suppliers must adhere to this Code while conducting business with or on behalf of Acrisure. Suppliers shall monitor their compliance with this Code and shall promptly report any violations (actual or suspected) of this Code to Acrisure.

Supplier Parties should be informed of the existence and contents of this Code. Suppliers should also ensure that any vendors or third parties that they use who are involved in providing products or services to Acrisure adhere to the principles in this Code.

Suppliers should not retaliate or take disciplinary action against any Supplier employee or other associated person who has, in good faith, reported violations of this Code, or who has sought advice regarding this Code.

Acrisure reserves the right to conduct reasonable inquires to verify a Supplier's compliance with this Code. Acrisure has no obligation to conduct such audits.

Acrisure may consider terminating its business relationship with any Supplier that does not comply with the standards set forth in this Code.

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¹ As used herein, the term “government official” is broadly defined to include any individual (regardless of rank or position) (i) who holds a legislative, administrative or judicial position of any kind, whether appointed or elected; (ii) who exercises a public function; or (iii) who is an official or agent of a public international organization (such as the United Nations, the World Bank or the International Monetary Fund). The term “government official” also includes any official of a political party and any candidate for political office. In addition, the term “government official” includes any executive, officer, agent or employee of a government-owned or government-controlled business (such as a state-owned bank or utility, a sovereign wealth fund or a public university). A government official is any person who is acting in an official capacity for the entities described above, including a private consultant who also holds a position with, or acts on behalf of, a government, a public international organization or an enterprise owned or controlled by a government. Finally, the term “government official” also includes spouses and immediate family members of government officials and may include former government officials, depending on their previous rank and function.