Introduction

Operating in one of the most dynamic industries, Sanlam Angola is a financial services company that is part of a group with a footprint across Africa that seeks to satisfy the needs of individuals and organisations by providing financial advice, services and products. Our purpose is to empower generations to be financially confident, secure and prosperous.

We recognise the identity of each of the peaple in the Sanlam Angola Seguros, the unique circumstances in respect of the regional culture according to local diversity in which they operate and the diverse nature of the stakeholders of each of these businesses Units.

Our shared core values form the foundation of the Sanlam Angola and reflect what we believe, what we consider as important and what we want to guide our behaviour. These values underpin every aspect of all our business dealings, irrespective of the business.

The Sanlam Angola Core Values are:

• Care: Serving with empathy and consideration. Knowing that everything we do leaves a lasting impact and legacy.
• Innovation: Always strive for continued improvement in order to create value for our stakeholders, our society and our world.
• Collaboration: Unlocking our winning-as-1 spirit by focussing on a better outcome for all, achieved through partnership and open-minded approach to everything we do.
• Integrity: Unwavering in our pursuit to do the right thing, resolute in our commitment to what is good for all stakeholders.

Ethical Conduct and Behaviour - Living the Sanlam Angola Values

Sanlam Angola regards high ethical standards as non-negotiable.

This Code of Ethical Conduct has been adopted to give effect to our core values. It guides our relationships with all our stakeholders, other relevant role-players and outlines our commitments to them.

Sanlam Angola’s Code of Ethical Conduct is binding on all directors, managers, employees, independent contractors, agents, service providers and business partners irrespective of their status as natural person, legal person or other entity.

The Code of Ethical Conduct will also be applied to establish the suitability of all prospective directors, managers, employees, independent contractors, agents, service providers and business partners irrespective of their status as natural person, legal person or other entity, prior to their appointment by Sanlam Angola.

Living the Sanlam Angola values means that Sanlam Angola and every person bound by this Code must commit and adhere to the following tight principles:

1. Our conduct shall at all times conform to the Sanlam Angola Core Values.

This means that we will at all times and wherever we may represent or be perceived to represent Sanlam Angola:

• Act honestly and fairly with due skill, care and diligence in the interests of Sanlam Angola stakeholders and the integrity of the financial services industry, having due regard and respect for diversity;
• Avoid any act that reflects adversely on our honesty, trustworthiness or professional competence;
• Accept accountability for all our actions and decisions;
• Refrain from any behaviour that can be classified as unlawful discrimination or harassment;
• Not tolerate any form of unlawful or criminal conduct including, but not limited to, bribery and corruption; and
• Ensure a culture of responsible corporate citizenship including, but not limited to, promoting the importance of a sustainable environment.

2. We are committed to complying with all applicable legislation, laws, regulations, codes and standards.

This means that:

• We are committed to conducting our business ethically, responsibly and in compliance with all applicable legislation, regulation, adopted industry codes and -standards as well as adhering to all internal policies and sound corporate governance principles to which we have committed to.
• We have no appetite for deliberate or purposeful violations of legislative or regulatory requirements, adopted industry codes and standards, internal policies or governance principles.
• We will seek to conduct our business with due skill, care and diligence in order to minimise violations arising from negligence.
• We will not tolerate any form of financial crime, including bribery and corruption in all its forms.

3. We are committed to fostering and maintaining an equitable and sustainable employer-employee relationship, including the provision of a safe, healthy and productive working environment.

This means that:

• Sanlam Angola subscribes to the principles of the International Labour Organisation and complies with all relevant labour laws.
• We respect the right of employees to work in an environment that is free from any form of unlawful discrimination or harassment.
• We subscribe to the principle of equal opportunities and strive to create a working environment which is inclusive and embracing of diversity.
• We shall maintain a healthy and productive work environment and comply with all applicable health and safety policies.
• We shall not tolerate the abuse of controlled substances or liquor or being under the influence of liquor or illegal drugs whilst at work.
• We shall not tolerate the sale, distribution, possession, or use of illegal drugs or substances in the workplace.

4. We shall protect and maintain the property and information of Sanlam Angola, its employees and its clients.

This means that:

• The assets and property of Sanlam Angola, including information gained and collected in the course of business, shall be used only for the business purposes for which they are intended.
• The protection of property includes ensuring the privacy of client and employee information and the safeguarding of intellectual property.

5. We shall manage and mitigate all conflicts or perceived conflicts of interest.

This means that:

• We will avoid any conflict of interest and share and declare any information that may cause a conflict or perceived conflict of interest.
• Where it is not possible to avoid a conflict of interest, we shall manage the potential conflict of interest.
• We will not do anything that may be regarded as an attempt to exert influence in unduly favouring any party, including the offering, giving or receipt of any gift or gratification which may have such effect.

5. We encourage persons to report any unlawful conduct or violations or suspected violations of this Code and shall provide protection for any person who make such reports.

This means that:

• We will create an environment that is conducive to the reporting of unlawful conduct, violations or potential violations of this Code and encourage all stakeholders to freely report any knowledge or suspicions of such unlawful conduct, violations or potential violations.
• We have made a facility, the SanlamAllianz Confidential Reporting Hotline managed by an independent third-party provider and to be used by all SanlamAllianz subsidiaries including Sanlam Angola, available to all employees and other stakeholders to report any knowledge or suspicion of unlawful conduct, violations or potential violations of this Code.
• We will ensure, with the assistance of our independent third-party provider, the anonymity of any person who prefers to remain anonymous when making a bona fide report, either directly to Sanlam Angola or via the SanlamAllianz Confidential Reporting Hotline.
• We will not tolerate any form of victimisation or retribution against anyone who attempt to uphold this Code or attempt to report unlawful conduct or a violation or potential violation of this Code.
• Any contravention of this Code will be regarded as a serious matter and appropriate disciplinary action will follow after due consideration of the circumstances of any breach.

Monitoring and Enforcement

Sanlam Angola will:

• not tolerate any contravention or violation of the Code of Ethical Conduct;
• participate in a SanlamAllianz committee to manage, monitor and report (including Sanlam Angola’s) ethical conduct;
• designate senior officials to monitor compliance;
• provide safe mechanisms for reporting breaches of this Code;
• investigate any alleged breach of this Code; and
• take appropriate action to remedy the breach.

Where to Obtain Guidance

Every employee has the right and responsibility to ask questions, seek guidance and express concerns regarding compliance with this code or the related implementation instructions of the guidelines.

There are detailed Sanlam Angola policies regarding the various issues and principles supporting the Code which are available on the SanlamAllianz Knowledge Exchange (KX) portal and electronically. These will provide further guidance to employees.

If you need guidance on any ethical issue that concerns you, you can contact the following sources for assistance (whistle blowing contact details):

• Your own supervisor or manager.
• Your Human Capital manager or compliance officer.
• The SanlamAllianz Risk and Compliance or Human Resources office (ethics@sanlamallianz.com).

The SanlamAllianz Confidential Reporting Hotline (“the Hotline”) is operated by an independent third party and guarantees anonymity. The Hotline may be accessed in the following ways:

Telephone: you may contact the Hotline via the contact numbers which have been created in specific countries where SanlamAllianz has a presence. Please refer to the attached list to view the list of countries with their contact numbers.

Email: sanlam@tip-offs.com

On-line report: www.tip-offs.com

Your request for help will at all times be treated as strictly confidential.