keeping promise - knights of columbusupdated our code of ethics and conduct (“the code”) for...

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Knights of Columbus

K E E P I N G the

P RO M I S ETo You a N d Our Order

At 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.

When Venerable Father Michael J. McGivneygathered a group of men in the basement

of 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, but the 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 Knight

Message from Supreme KnightCarl A. Anderson

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Knights of Columbus Founding Principles and Core Values

Father 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.

This Code of Ethics and Conduct demonstrates how our Core Values guide us in situations that we may encounter.

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CONTENTS

Knowing the Role of Our Code ......................................................................................1

KEEPING 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 .........................................................2

Responsibilities for Management................................................................................2

KEEPING THE PROMISE TO THE ORDER ...........................................................4Finding Help and Reporting Matters of Concern.....................................................4Explanation of Reporting ..........................................................................................4

Contacts 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 ............................................................9

Intellectual Property .......................................................................................................9Using the Order’s Systems Properly ..........................................................................10

Appropriate Use.........................................................................................................10Reputation at Risk .....................................................................................................10Internet and Email Use ............................................................................................10

Participating in Social Media .......................................................................................11

KEEPING 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..........................................................................13

Preventing Harassment and Discrimination ...........................................................13Practicing Corporate Ethics..........................................................................................14

KEEPING THE PROMISE TO OUR MEMBERS AND COMMUNITIES.....15Respecting the Environment .......................................................................................15Understanding Anti-Corruption .................................................................................15Relationships with Public Officials ........................................................................15Facilitating Payments................................................................................................15

Preventing Fraud.............................................................................................................15Money Laundering.........................................................................................................16 Ensuring Service Quality ..............................................................................................16Engaging in Ethical Sales and Marketing ................................................................16Following Competition Laws.......................................................................................17Prohibited Agreements with Competitors ..........................................................17Handling Competitive Information.......................................................................17

Abiding by Trade Controls ............................................................................................17Boycotts and Restricted Countries/Sanctions ........................................................18Participating in Community Interests ......................................................................18Political Activities ......................................................................................................18

CONTENTS

Knowing the Roleof Our Code

Our 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.

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.

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Question or Concern? You may contact the Chief Compliance Officer at extension 4122, call the Ethics Helpline at 855-806-7346, or visit https://reportlineweb.com/kofc to make a report.

QWhat 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.

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KEEPING THE PROMISE

MEANS. . .Following Our Code and the 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) • Employees • Interns and Students• Agents• Contractors of the Order, its subsidiaries,

and affiliates

Additionally, our business partners, consultants,vendors, and suppliers must be familiar with ourCode and conduct themselves according to similarprinciples.

Following Corporate and BusinessUnit Policies

Corporate 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.

We 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 comply with 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 of

laws, 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.


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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 contained

in this Code and related policies• Be a role model. Lead with integrity and promote a culture of ethics and

respect. • Make sure all business records are accurate and well-maintained • Foster a safe, healthy working environment where all employees receive fair

and respectful treatment• Support your team and help them understand what is expected of them. • Keep an open-door setting that encourages questions, feedback, and

reporting • Understand your obligation to report behavior that

violates the Code, our policies or the law • Utilize the resources listed in the “Finding Help and Reporting Matters of

Concern” section• Never put business results ahead of ethical conduct or compliance with the

Code 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.


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Finding Help and Reporting Matters of ConcernExplanation of Reporting

If you are unsure whether a particular situationviolates our Code or the law, it is vital to askquestions. Issues that are not a direct violation maystill affect our reputation and must be reportedimmediately. e earlier we investigate and correctpotential violations, the better our chances ofpreventing an issue from escalating.

Some examples of issues that you must always report include, but are not limited to:

• Any action that might lead to incorrect financialreporting

• Any unlawful or illegal act• A violation of the Code or the Order’s policies• Any other action that contradicts our Core

Values

Zero Tolerance for RetaliationIf any personnel from any level of the Order

reports misconduct in good faith, the Order willprotect that person from retaliation. Making areport in good faith means to have an honest beliefthat the information is as accurate as possible andthat there is a legitimate reason for concern.

The Order prohibits discrimination, harassment,and bullying in any form. We take all claims ofretaliation seriously, investigating each onethoroughly and taking appropriate action. If you feelyou have experienced this from anyone at the Order,or by a partner or vendor of the Order, immediatelyreport the incident to your manager, HumanResources, or the Chief Compliance Officer.

Contacts for ReportingYou may always contact the Chief Compliance

Officer, call the Ethics Helpline, or visithttps://reportlineweb.com/kofc to make a report.You may remain anonymous when using theHelpline or website.

Making the Right ChoiceIf you’re faced with an ethical dilemma and

you’re not sure what to do, ask yourself:

• Is it legal?• Does it comply with our policies?• Is it consistent with our core values?• Is it consistent with our long-term goals and

interests?• Would I be comfortable with my decision if it

was made public?

If your answer to any of these questions is NO,don’t do it, and seek further guidance.

KEEPING THE PROMISETO THE ORDER


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All Reports Will Be InvestigatedAn objective, independent, and knowledgeable

team will be assigned to conduct or supervise theinvestigation. They will determine the facts throughinterviews, a review of documents, and otherappropriate means.

Complete Reports and Follow-UpInformationAll reports or questions regarding our Code, policiesof the Order, or the law should be as detailed aspossible. Important information to provide includes:

• Names of those involved (including otherwitnesses)

• Times and locations of any incidents• Any documentation regarding the incident or

allegation • Your contact information unless you are making

an anonymous report

Responding to Code Violations in aFair and Consistent Manner

If an investigation reveals there has been aviolation, the Order will take appropriatedisciplinary action. Personnel who violate the Code,applicable laws, regulations, policies, or contracts aresubject to disciplinary actions up to and includingtermination of employment or service, regardless ofthe level of their position at the company. TheOrder is committed to providing a safe andsupportive work environment where everyone istreated with respect, fairness, and dignity. This is anintegral component of a positive, healthy, andsuccessful working environment.

Avoiding Conflicts of InterestA conflict of interest arises when your interestsconflict with the business interests of the Order.Examples include:

• Owning a financial interest in anotherorganization that sells insurance products

• Having a personal or family interest in atransaction with the Order

• Accepting unreasonable gifts from a vendor orsupplier

Annually, all employees are required to sign aConflict of Interest Disclosure Form. If a conflictarises, you must disclose it promptly and seek toresolve it immediately.

Most concerns about conflicts of interest canbe resolved and appropriately addressedthrough prompt and complete disclosure tothe Chief Compliance Officer.

Working With Family and FriendsWhile our policy does not prohibit the

employment of relatives, in order to avoid conflictsof interest or favoritism, employees may not workdirectly for, supervise, or make employmentdecisions about a family member without firstadvising Human Resources of the relationship. Forfurther information, please see the Employment ofRelatives Policy found in your Employee Handbook.You will find Employee Handbooks for managementand bargaining unit employees in Kronos.

You must disclose any relationship with a familyor friend (or their company) to your manager, toProcurement, or to Human Resources before wehire or contract with them for goods or services.

Q The Order just started using a new third -party vendor and it is a company in whichI own stock. Is that a conflict of interest?

Possibly. The best course of action wouldbe to disclose this information to yourmanager and to the Chief ComplianceOfficer so that the situation can bereviewed.

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Financial Interest in Other BusinessesPersonnel must not make or hold investments in

a company that would create a conflict of interestwith their duty of loyalty to the Order. Holding asignificant business interest in a company which is acompetitor or a business partner of the Order couldput your personal financial interests at odds with theOrder's best interests, which is impermissible. If youthink you might own a significant investment in acompetitor or business partner which could createsuch a conflict of interest, you must disclose this tothe Chief Compliance Officer who will providefurther guidance and possibly require divestiture ofsome or all of the investment.

Outside EmploymentEmployment with other companies is

allowed as long as it does not impact your workwith the Order. Company time and companyassets may not be used for any outsideemployment. Personnel may not imply in anyway that other employers are endorsed by theOrder.

Corporate OpportunitiesWe must not take advantage of any

knowledge or information gained in working atthe Order to enrich ourselves, our families, orothers financially. This includes taking anybusiness or investment opportunities discoveredthrough our position at the Order.

Gifts and EntertainmentConflicts of interest can easily develop around

the giving or receiving of gifts or entertainment inthe course of our business relationships on behalf ofthe Order.

If gifts, meals, and entertainment meet the followingcriteria, they may be acceptable:

• Infrequent• Very small in value• Unsolicited• Not made in cash or cash equivalents

(such as gift cards) • In compliance with all applicable laws and

regulations • Customarily offered to others having a similar

business relationship

The Order’s Gift and Entertainment Policy islocated on the Order’s intranet site in the CorporatePolicy Center.

As a rule, personnel should not accept any gift,meal, or entertainment valued at over $100, or giftcards or other “cash equivalents” in any amount.Any attempts by others to provide you with gifts,meals or entertainment over $100 in value, or giftsof cash equivalents, must be reported to the ChiefCompliance Officer, who will decide how the

Q Simone’s brother-in-law Joshua isinterviewing for a job in her department.are they allowed to work together?

Probably. Simone must inform HumanResources that a close relative is acandidate for hire. as long as Simone andJoshua will not supervise or evaluate oneanother, a conflict of interest probablydoes not exist.

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Q during the holidays, one of our vendorssent me a gift card to a local restaurant.May I accept it?

No. a gift card is a cash equivalent and itwould violate our policies to accept it.after notifying your manager and theChief Compliance Officer, you shouldpolitely thank the vendor but return thegift card and let them know about ourcompany’s gift and entertainment policy,which is located on the intranet site inthe Corporate Policy Center of iLink.

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matter will be handled. This also applies to anyattempts by others to reimburse hotel or othertravel or meeting expenses on your behalf.

Ensuring Ethical Record KeepingEach of us plays a role in assuring the integrity

of our business records. Such records include:

• Financials and other Statements of Income orBusiness Results

• Invoices and statements • Payroll and timekeeping • Expense reports and accounts • Agent and member information and data • Reports to government agencies and any other

public reports

All entries, member records, corporate funds,and assets must be recorded accurately and inaccordance with the Order’s procedures. Nevershould an entry intentionally conceal the truenature of any transaction or event. It is especiallyimportant that Financial Records are clear and thatwe explain, with words, any numbers that couldhave more than one meaning.

You should never participate in unethical record-keeping activities, such as:

• Making false statements (whether verbal orwritten)

• Altering sales information • Overstating or understating assets, liabilities, or

any other figures that could mislead customers,regulators or rating agencies.

• Hiding or incorrectly accounting for Orderfunds

Financial documents that the Order discloses tothe public and other stakeholders must be accurateand honest. is includes marketing materials andpublications that report financial information andresults. If you find inaccuracies, you must notify theappropriate personnel immediately. Do not alterrecords without first receiving authorization.

If you know about, or suspect, any violations ofour Code or policies involving accounting, internalcontrols, auditing matters or records, please

immediately report your concerns to the ChiefCompliance Officer or Internal Audit Department.

Record RetentionYou must be aware of, and follow, internal

procedures and applicable laws when storing,maintaining, and discarding paper and/or electronicbusiness records.

Do not tamper with or manipulate records, ordestroy them prior to their expiration dates. eprocedure for determining document expirationdates is set in the Records Management Policy andRecords Retention Schedule located on the Order’sintranet site in the Corporate Policy Center.

e Order recognizes that it is good businesspractice to retain and manage records in aconsistent, systematic, and reliable manner,so that they can be retrieved promptly whenrequired for legal, regulatory, or operationalreasons.

QGeoff often receives vendor invoices andsends them for internal review andpayment processing. He located oneinvoice that had been misplaced on hisdesk for months. Too embarrassed tosend it for payment after the due datehad passed, he contacted the vendor andasked them to issue a new invoice with acurrent due date. Is this acceptable?

No. Regardless of why the invoice wasnot paid on time, asking a vendor toalter an invoice is never the right thingto do. Geoff should have immediatelytalked to his manager for assistance inhandling the matter.

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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.

Communicating With Regulators,Attorneys and InvestigatorsOccasionally we may be asked to collect or retrievedocuments and other data for:

• Internal or external audits• Internal or external investigations• Litigation• Other informal inquires

Once it is determined that the requestor has theappropriate authority to collect this information,promptly and completely provide all requested data.Never conceal, alter, or destroy requested records.Always respond appropriately, accurately, timely,and respectfully to inquiries. Never attempt to exertimproper influence on the results of an investigationor audit. Remember that you must cooperate fullyand timely with any internal Compliance or LegalDepartment investigation.

If you receive a request from a regulator,attorney, or investigator for records, documents, orother information, immediately contact the LegalDepartment or the Chief Compliance Officer sothat they can confirm that the request is valid.

Responding to Media InquiriesWhen communicating with the media, it is

important that we speak with one consistent voice.Only those designated to do so by theCommunications and Strategic Planningdepartments can make public statements on theOrder’s behalf. is is to ensure that responses tooutside inquiries preserve the Order’s reputation forintegrity and professionalism. We will provide anaccurate and honest picture of our operations to thepublic. If you have any questions, or have received arequest from the media, please contactCommunications and Strategic Planning.


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Protecting the Order’s AssetsWe have a shared responsibility to protect and

properly use the Order’s assets. Use of all companyassets is for legitimate business purposes only. eft,carelessness, and waste have a direct impact on theCompany's profitability. e Order’s Acceptable UsePolicy is located on the Order’s intranet site in theCorporate Policy Center.

Physical Property and FacilitiesWe must protect our facilities, equipment,

vehicles, computers, and funds from theft,inappropriate use, and damage. Only use theseshared assets for legitimate business purposes, andnever use any Order asset to take part in prohibitedconduct. If you suspect any form of fraud or theft,you should report it immediately to your manageror the Chief Compliance Officer.

Confidential and ProprietaryInformation

Safeguarding confidential and proprietaryinformation, such as material that could be of use tocompetitors or harmful to the Order if disclosed, isvital to the security of the Order. is includescontract documentation and corporate strategies.When using electronic resources such as laptops,ensure they are physically secure and passwordprotected at all times. e use of passwords on oursystems and networks is mandatory. If you believean electronic resource has been compromised,immediately contact your manager or InformationTechnology Security.

We should never communicate such informationto outside parties unless there is a legal obligation todo so, or the Order has authorized such acommunication. Do not disclose such informationto unauthorized persons or companies.

We are also responsible for recovering anylost/misplaced confidential information whenpossible, and for preventing further unauthorizeduse or disclosure. e safeguarding of private andsensitive material must continue even afteremployment with the Order has ended.

Intellectual PropertyThe Order’s valuable intellectual property (IP) includes:

• Copyrights• Patents• Trademarks• Service marks• Trade secrets • Design rights • Logos• Knowledge of business workings• Intangible industrial or commercial property

We work diligently to protect the Order’sintellectual property. We must safeguard theseimportant business tools. You should report anysuspected misuse of the Order’s intellectual propertyto the Legal Department. A copy of our policy islocated on the Order’s intranet site in the CorporatePolicy Center.

When using third-party confidential informationand intellectual property such as software, we mustprotect it as we would protect our own property andcarefully follow all applicable license terms. We mustnever knowingly infringe on the copyrights,trademarks, or patents of others. We may notdownload unlicensed software onto Companycomputers or duplicate, publish, or distributecopyrighted materials. We will not download songs,photographs, and/or videos without consent from therightful owner. In addition, we will not disclose or usethe confidential information of former employers.


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Using the Order’s Systems Properly

appropriate UseThe following electronic assets of the Order are tobe used only for conducting its business:

• Desktop and laptop computers • Cellular phones • Tablet computers • Email• Internet access • Network resources • Software resources• Telephones• Copying and printing equipment

We trust that you will use our company assetsappropriately and protect them from loss, damage,theft, waste, and improper use. ese resources areintended to advance the success of the company.Unauthorized use of these assets can result indiscipline. An example of inappropriate use includesthe communication of a discriminatory orthreatening message. We may not use these systemsto view or communicate sexually explicit orotherwise inappropriate material, or to conductwork on behalf of another business or organization.Do not use, borrow, or loan company assets withoutpermission.

If you have any questions about the use ofelectronic assets such as computers, telephones,email and internet access, please consult theAcceptable Use Security Policy located on theOrder’s intranet site in the Corporate Policy Center.

Reputation at RiskWhile social media, email, and other online

tools are integral to our ability to compete andcommunicate, if misused they can also bedetrimental to your personal reputation and thereputation of the Order. Always maintain arespectful and professional demeanor in any forum.Never speak on behalf of the Order unless expresslygiven authority to do so.

Internet and Email UseWe must be respectful in our use of the Order’s

resources, including internet access. Do not spendan excessive amount of time on the internet or usethe Order’s resources inappropriately. e Orderreserves the right to block offensive, illegal, andnon-business-related sites, as well as sites deemeddangerous to the security or operation of the Order’scomputing assets.

Take the same care composing and sendingemail, instant messages, and text messages as youwould in composing any other Order document.Electronic messages, both personal and business-related, are lasting and recoverable written recordsthat can easily be copied and forwarded worldwidewithout your knowledge or consent.

e Order may inspect or monitor all businessresources, assets, and property without the priorapproval, knowledge, or consent of employees to theextent allowed by law. is includes monitoring andretrieving information that is stored or transmittedon electronic devices, computers, and systems.



Participating in Social MediaWe must always use social media in a way that

is respectful and professional. e Order reservesthe right to monitor, restrict, and access the use ofsocial media in the workplace.

Should you encounter any negative messages orrequests for official Order participation in anysocial media, refer these issues directly to theCommunications and Strategic Planningdepartments. Under no circumstances should youuse social media to engage in harassment of anykind or to distribute confidential or proprietaryOrder information. Never allow the use of socialmedia to conflict with responsibilities of the Orderor the ability to complete regular work duties. Byenforcing this policy, the Order does not intend torestrict lawful communications and the sharing ofinformation among our employees. Agents shouldalso refer to the Social Media Guidebook for theKnights of Columbus Field Force, which containsspecific policies for the use of social media relatedto the Order’s insurance business.

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Marcia enjoys updating her social mediaaccounts during the day and hasrecently begun livestreaming videos toFacebook from the office. Jan sits in thecubicle next to Marcia and is concernedabout her privacy so she asked Marcia tolimit her recording to times when Jan isnot at her desk. Is the problem solved?

No. It is not acceptable to livestreamfrom the office. There is a potential forconfidential information to be disclosedand it can be an invasion of privacy tothose around you. Jan should notify theChief Compliance Officer.


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Preventing Insider TradingWhile the Order is not a publicly traded

company, it does have a registered investment advisorsubsidiary and many of our business partners arepublic companies. We may not buy or sell the stockof our vendors, business partners, or investmentadvisory customers based on any information welearn during our business relationships. Trading stockusing this information is considered insider tradingand is illegal. We must not give advice to others

based on inside information. is is consideredtipping and is illegal. We must protect thisinformation just as we protect any confidential andproprietary third party information.

It is important for us all to act professionally andbe cautious when discussing the Order’s businessoutside of the workplace. e security laws thatrelate to these matters are complex, so please contactthe Legal Department or the Chief ComplianceOfficer if you havequestions.

Safeguarding InformationWe are committed to the privacy of both

member and employee information, and we protectprivate information by following our guidelines forits collection, storage and use. Examples of privateinformation include:

• Medical history• KofC Member list - which identify members as

Catholic - and are therefore protected-- even ifthey only provide name and address.

KEEPING THE PROMISETO EACH OTHER AND OUR PARTNERS

QCraig is a manager in the mailroom.One of his employees informed himthat a package received from aGeneral agent was open and itscontents were missing. The employeewas concerned that the package mayhave contained nonpublic personalinformation on an insurance member.How should Craig handle thissituation?

Craig must immediately contact theChief Compliance Officer. allemployees of the Order must takeseriously our commitment to protectthe private information of ourmembers. The Order must fullyinvestigate any potential loss ofmember or employee privateinformation and may be required todisclose to regulators the occurrenceof such loss.

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• Employment history • Marital status • Government-issued identification numbers • Exam and test results • Financial information (such as bank accounts

and payment cards)

Whenever job responsibilities include the use ofmember or employee data, we have a duty to knowand comply with the privacy and data protectionlaws that apply to our work. For more informationon our data protection guidelines, please see theAcceptable Use Security Policy, found on the Legalpage of iLink. If you have any questions, pleasecontact the Director of Information TechnologySecurity.

Maintaining Safe WorkplacesHealth and Safety Concerns

We are committed to providing a safe andhealthy workplace. To achieve this, we must complywith all applicable health and safety rules andregulations, as well as all posted safety procedureswithin our areas of operation. If you are aware ofany unsafe working conditions or have concernsabout your safety, immediately inform yourmanager, a member of the Health and SafetyCommittee, the Director of Facilities, or Security.

Substance abusee Order has a zero-tolerance policy with

regard to substance abuse and is committed tokeeping the workplace free from drugs and alcohol.You may not come to work while under theinfluence of alcohol, illegal drugs, or misusedmedications. e only exception to this policywould be for an authorized Order event wherealcohol is served after business hours.

Violence and disruptive BehaviorNever engage in or tolerate any form of violence

including threats, intimidation, or acts ofaggression. If you know of actual or potentialworkplace violence, you should immediately reportyour concerns to your manager, or Security.

We do not condone unprofessional, disruptivebehavior that creates a difficult work environment.All personnel have a duty to report any instances ofdisruptive behavior to their manager, Security orHuman Resources.

For additional information on these topics,please see the appropriate Employee Handbook inKronos.

Preventing Harassment andDiscrimination

The Order is committed to providing a workenvironment in which all individuals are treatedwith respect and are free from harassment.

Harassment can be sexual or non-sexual innature. Sexual harassment includes conduct such asunwanted advances, sexual jokes, and sexuallysuggestive comments. It also includes touching,requests for sexual favors, and inappropriatecomments about another’s appearance. Non-sexualharassment may include offensive comments, jokes,or pictures.

The Order provides equal employmentopportunities and fair treatment to all individuals.

Q Jim’s manager emailed a joke to variousmembers of his department. The jokewas inappropriate and offensive to someof the employees who read the email.When asked, Jim’s supervisor said he didnot mean to offend anyone and it was “allin good fun.” Should Jim report thematter?

Yes. Regardless of whether thesupervisor’s email constituted illegalharassment or unlawful discrimination, itcould be viewed as offensive and will notbe tolerated. The Order also protects Jimfrom retaliation for reporting hisconcerns.

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We must provide an inclusive work environmentthat reflects the diversity of the communities inwhich we operate. We will demonstrate respect forall of our co-workers, members, customers, andbusiness partners. We do not make employment-related decisions or discriminate against anyonebased on any characteristic, as prohibited byapplicable law. We believe that everyone should betreated with fairness, respect, and dignity. We expectour business partners to act in a way that isconsistent with our sense of fair treatment and equalopportunity.

We can find strength in diversity. Different peoplehave different perspectives on issues, and that canbe valuable for solving problems or generatingnew ideas.

Practicing Corporate EthicsAs part of our commitment to corporate ethics:

• we uphold individual human rights and providereasonable working hours and fair wages andexpect the same of our suppliers, vendors, andother business partners.

• we follow the laws regarding wages and workconditions, and ensure that our fellowemployees are treated with respect.

• we have a zero-tolerance policy for businesspartners who do not share the same values,especially if they condone the use of forced laboror human trafficking practices. The Order will not knowingly do business with

partners who violate these policies.

We seek business partnerships that align with ourcore values and follow the highest standards ofbusiness conduct. We perform due diligence andknow our business partners, consultants, agentsand others with whom we conduct our business.

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Respecting the EnvironmentThe Order is fully committed to acting as an

environmental steward in all of its locations ofoperation. To reduce our environmental footprint,we constantly strive to maximize the efficient useof natural resources during our workday. Weencourage you to submit any suggestions regardingthis goal to Human Resources or the Director ofFacilities.

Understanding Anti-CorruptionWe must know and follow the anti-corruption

laws that apply to our work. Employees workingwith third parties in other nations, or workingoverseas in any capacity, for any length of time,must be particularly careful. It is necessary to befamiliar with restrictions on bribery of foreigngovernment officials and commercial partners.Generally, any attempt to influence governmentemployees (or members of political parties orroyalty) at any level, by providing gifts orentertainment in return for a business advantage,could be a bribe.

We are never permitted to offer or accept a“kickback.” This means we may not accept anythingof value from a business partner or member forwhom we have provided revenue, products orservices, and we may not provide anything of valueto someone who has provided a product or serviceto the Order.

Relationships With Public OfficialsWe must be cautious and transparent in our

relationships with public and government officials.Never create the impression that we seek toinfluence the decision making of any governmentemployee.

Facilitating PaymentsIn certain parts of the world, government

officials commonly receive so called "facilitating" or"expediting" payments to advance or secure theperformance of routine governmental actions suchas issuing permits or providing police or fireprotection. Order personnel must never participatein this practice even if it appears customary.

Preventing FraudWe must remain vigilant in preventing,

detecting, and deterring identity theft and fraud.The Order maintains an Anti-Fraud Plan, which islocated on the Order’s intranet site in the CorporatePolicy Center.

The purpose of the Anti-Fraud Plan is to ensurethat the Order has in place reasonable policies andprocedures designed to detect, investigate, andprevent all forms of insurance fraud that may occurin our day-to-day operations. If fraud is detected,

KEEPING THE PROMISETO OUR MEMBERSAND COMMUNITIES

QOne of our vendors asked me if theremight be a position in the Order for hisdaughter. He said he would be veryappreciative of anything I could do to helpand patted his wallet. What should I do?

any suggestion by a business partner thatsomething of value would be provided inreturn for a favor is not permitted andshould be reported to the ChiefCompliance Officer. We do not partnerwith businesses who employ such practicesor who make inappropriate suggestionsthat imply a kickback will be paid for abusiness or personal favor.

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the Order will conduct a prompt and thoroughinvestigation and will take appropriate disciplinaryand legal action, including reporting to authoritiesas required.

We are all committed to integrity and avoidingany instances of fraud during the course of theOrder’s business. Any employee who becomes awareof or suspects identify theft or fraud must report itimmediately to the Chief Compliance Officer.

Money LaunderingMoney laundering is the process by which

persons or groups try to conceal illegal funds ormake the sources of their illicit funds looklegitimate. The Order’s AML Program establishesthe policies, procedures, and controls to ensure thatemployees do not engage in or unknowingly assistothers in engaging in money laundering. EachOrder employee who administers, sells, or servicesany covered insurance product must be familiarwith and comply with the Order’s AML Program.Any person who becomes aware of suspiciousactivity indicating potential money launderingactivities must immediately report it to the ChiefCompliance Officer.

Ensuring Service QualityIntegrity, Professionalism, Excellence, and

Respect should drive all of our relationships withour members, customers, and each other. We mustalways follow our internal procedures diligently.Speak with your manager or supervisorimmediately if you learn of any issues relating toquality control or unacceptable performance.

These standards hold especially true for thosewho sell our products. Personnel catering toinsurance clients must know both our productsand those of our competitors. They should alsoknow the impact of tampering, exchanging,changing, reducing, or otherwise amending amember's present insurance program. Changesshould not be made to a member’s program unlessthe changes benefit the member in some way.

Engaging in Ethical Sales and Marketing

We must engage in fair dealing practices at alltimes. Personnel involved in selling, advertising,promoting and marketing our products must ensurethat our business conduct is always guided byintegrity and professionalism. This means behavingwith accuracy and honesty when representing thefeatures and costs of our products. It also meansnever making unfair or inaccurate comparisonsbetween our competitors’ products and our own.We must always keep our Core Values in mindwhen engaging in sales and marketing activities andnever conduct ourselves in a manner that mightbring negative attention to the Order.

Q Steven is a Field agent who sells the Order’sinsurance products. after meeting with apotential new customer, he is concernedbecause the applicant asked unusualquestions about changing addresses andtaking out loans against the insurance policy,and refused to clearly provide all of hisidentifying background information. Is thereany action Steven should take, based on hisconcerns?

Yes. Steven and his General agent mustensure that their supervisors and the ChiefCompliance Officer are informed of Steven’sobservations and concerns. We each have aresponsibility to communicate any unusualactivity that we notice. Steven has foundseveral red flags that could indicate possibleidentity theft, fraud or money laundering, sohe must take extra precautions. Even if helater finds that the applicant is a legitimatepurchaser, the Order protects him fromretaliation for reporting in good faith.

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When dealing with our members and their families,follow these policies:

• Keep informed and fully comply with all stateand provincial laws and regulations, as well asthe rules of the Order, when soliciting or sellingthe Order’s Insurance products

• Never endorse, deposit cash or negotiate anycheck payable to the Order when soliciting orselling the Order’s insurance products

• Only use sales materials approved by the Order• Do not publicize or advertise the Order's name

in any medium including newspapers,magazines, websites, social media, radio, councilor state bulletins unless the content of themessage has been submitted to the SupremeCouncil and authorized in writing

• Do not sign as a witness to any person'ssignature, or any application or other paperrelating to the Order's business, unless thesignature occurs in your presence

• Do not sign the name of any other person,whether or not the person consents

• Deliver all policies and contracts to therespective owners without delay, and re-explainand review the plan

• Never alter or modify policies, illustrations, orany other printed material issued from ororiginating at the Supreme Councilheadquarters

• Ascertain that insurable interest exists beforewriting an application for insurance

• Present honestly and accurately all factsnecessary to enable a member to make aninformed decision

Following Competition LawsWe all must act with integrity and respect for

our competitors and members when competing forbusiness. We support ethical and lawful competitionso our customers can receive superior service at anappropriate and fair price. Laws regardingcompetition can be complex, but there are somebasic ways to keep the marketplace open andhonest.

Prohibited agreements WithCompetitors

We cannot enter into any formal or informalagreements with our competitors that may restrainfree and open trade. Agreements that seek to fixprices, rig bids, or divide and allocate markets orcustomers are illegal. Be careful not to share ourconfidential or proprietary information with ourcompetitors, as it could lead to prices or practicesthat adversely affect our customers. In a situationwhere a competitor wishes to discuss any of thesetopics, immediately end the conversation and reportthe activity to the Chief Compliance Officer or theLegal Department.

Handling Competitive InformationCompetitors’ non-public, confidential, or

proprietary information should never be sought orobtained. Typically, data such as costs, internalcustomer lists, and marketing strategies are notavailable publicly. We cannot seek or use suchinformation obtained through third parties orformer employees. It is forbidden to use deception,such as posing as a potential customer, to find outcompetitor information.

Abiding by Trade ControlsIt is critical that we carefully comply with all

national and local rules and regulations that governour international trading activity. We must alwaysunderstand and follow laws relating to exports, re-exports, or imports from the U.S. and, in certaincircumstances, overseas.

An export is a product, service, technology, orpiece of information that is shipped to a person inanother country. An export can also occur whentechnology, technical information, or software isprovided in any way (including verbally, in the caseof information) to a non-U.S. citizen located ineither the United States or another country. Beforeengaging in exporting activity, you must verify theeligibility of both the location of delivery and thespecific recipient. You must obtain all required


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licenses and permits, and pay all proper duties. This can be a very complex area of the law, so if youhave any questions, please contact the LegalDepartment.

Boycotts and RestrictedCountries/Sanctions

The Order is required to abide by economic andtrade sanctions which are administered and enforcedby the U.S. Department of Treasury’s Office of

Foreign Assets Control (OFAC) and Canada’s Officeof the Superintendent of Financial Institutions(OSFI). These sanctions may restrict the Orderfrom engaging in any business with sanctionedcountries or with specific individuals or entitiessubject to such sanctions.

We may also be approached to boycott certain

countries, companies, or other entities. Under U.S.law, we must not cooperate with any requestconcerning unsanctioned foreign boycotts (boycottsnot initiated by our government) or relatedrestrictive trade practices. This means we cannottake any action, furnish any information, or makeany declaration that could be viewed as participationin an illegal foreign boycott. There are severepenalties for violation of these laws. Further, we arerequired to report any suspected boycott requests tothe U.S. government. If you receive such a requestyou must immediately notify the Compliance andLegal Departments.

Participating in CommunityInterests

Political activitiesThe Order encourages all personnel to

participate in the democratic process and becomeinvolved in personal political activities. When we doengage in political activity, however, it must alwaysbe clear that we do so in a personal capacity and noton behalf of the Order.

We must never provide personal contributions toa political campaign in the name of the Order, andwe must never seek reimbursement for personalpolitical contributions.

Any contact we have with regulators, legislators,or other elected officials that may be viewed aslobbying, such as requests for administrative orlegislative action, should never be undertaken in thename of the Order. Personnel whose responsibilitiesmay be affected by lobbying laws must seek counselfrom the Legal Department to determine whetherdisclosure, registration, or other rules apply.

Regardless of the role you hold, take care not toexert pressure on others to accept or support yourpolitical point of view.

QSusan received an inquiry this morningfrom a member in Florida who wants topay for new memberships to the Orderfor his friends in Cuba. although Susanknows that the Order cannot acceptmoney directly from Cuba, she assumesthat if the money for the membershipfees does not come directly from Cuba itcan be accepted. Is she correct?

No. While the U.S. government has attimes relaxed certain restrictions againstCuba, in general most transactionsbetween U.S. persons and Cuba are stillprohibited. Regardless of whether thetransactions, products or services directlyor indirectly benefit an individual orentity in a sanctioned country, it may bea violation of U.S. Law and our ownpolicy to engage in the transaction,product or service. Because this is acomplicated situation Susan must contactthe Chief Compliance Officer or Legaldepartment for advice.

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CONTaCT INFORMaTION

COMPLIaNCE - 4122 or 4593

ETHICS HELP LINE: 1-855-806-7346 or [email protected]

Managers and employees also have the ability to enter their concerns online

using either of the links below:

MaNaGER FORM: https://tnw.reportlineweb.com/mgr/kofc

EMPLOYEE FORM: https://reportlineweb.com/kofc

1 COLUMBUS PLAZA • NEW HAVEN, CONNECTICUT 06510-3326 • TEL. 203-752-4000 • WWW.KOFC.ORG

4839 10/18

mailto:[email protected]

https://tnw.reportlineweb.com/mgr/kofc


WWW.KOFC.ORG

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