Code of Conduct

CODE OF CONDUCT

I. COMMON PROVISION

A. Applicability

The InLife Benefits Code of Conduct establishes the core standards that guide all employees, including supervisory and management bodies. It also extends to third parties, such as consultants, suppliers, and agents who represent the company, ensuring that they uphold the same principles of integrity and accountability.

B. Implementing Regulations 

The Code of Conduct is reinforced by implementing regulations that establish baseline standards of conduct, while allowing InLife Benefits to adopt additional measures as needed.

C. Duty to Comply 

All employees are accountable for understanding and adhering to the Code of Conduct and relevant internal regulations tied to their roles. Participation in both introductory and refresher training programs is mandatory.

D. Reporting Concerns 

InLife Benefits promotes a culture of transparency, encouraging employees to report any practices or actions that may breach the law, the Code of Conduct, or internal regulations. Reports may be submitted personally or anonymously, in writing or orally, and are handled with strict confidentiality in accordance with legal and internal provisions. Retaliation against employees who raise concerns in good faith will not be tolerated.

E. Breaches

Violations of the Code of Conduct or its implementing regulations by employees will trigger disciplinary measures in line with applicable local laws. Such breaches may further expose individuals to liability for damages or, where warranted, criminal prosecution.

II. RULES OF CONDUCT

A. Fair Conduct of Business

InLife Benefits is committed to conducting all business in full compliance with applicable laws, internal regulations, and the highest standards of professional ethics. Employees are expected to act with fairness and integrity, upholding the Code of Conduct, implementing regulations, and the InLife Benefits’s sustainability commitments. Managers, in particular, carry the responsibility of exemplifying these principles, serving as role models and fostering a culture rooted in ethics and compliance.

B. Sustainability

InLife Benefits is committed to driving economic and social progress anchored in respect for fundamental human and labor rights and the protection of the environment. A culture of sustainability is embedded across all spheres of influence—employees, customers, and suppliers ensuring that responsible practices are integral to our operations. Employees are expected to embody this commitment by:

1)     Valuing colleagues, fostering development, and recognizing individual contributions to organizational success.

2)     Enhancing community well-being and acting as responsible corporate citizens in partnership with institutions and associations.

3)     Leveraging the Group’s skills and resources to support vulnerable populations and promote inclusion of disadvantaged groups.

4)     Integrating environmental, social, and governance considerations into underwriting, investment, and procurement decisions.

5)     Reducing both direct and indirect environmental impacts through responsible practices.

The Charter of Sustainability Commitments defines the InLife Benefits’s sustainability model and priorities. Employees are required to align their actions with these commitments, ensuring the realization of the Group’s vision for sustainable growth and long-term stakeholder value.

C. Work Environment, Diversity and Inclusion

InLife Benefits is committed to fostering a dynamic and respectful workplace, free from discrimination and harassment. We actively champion diversity and inclusion, recognizing that collaboration among individuals with varied cultures, skills, perspectives, and experiences is essential to attracting top talent, driving innovation, and sustaining business growth.

Employees are expected to treat one another with respect, safeguarding personal dignity in all interactions. Managers carry the responsibility of fostering a supportive environment where integrity, cooperation, diversity, and inclusion are actively promoted.

All employment decisions including recruitment, training, evaluation, and advancement are based solely on merit and performance, free from bias related to race, ethnicity, religion, sexual orientation, marital status, or political views. Communication with employees must remain open, transparent, and fair, while professional training and development are encouraged as part of a broader framework to strengthen individual capabilities.

InLife Benefits upholds freedom of association and collective bargaining, firmly rejecting irregular work practices, exploitation, forced or compulsory labor, and child labor. Harassment, bullying, and mobbing are categorically opposed, ensuring a workplace culture built on respect, fairness, and accountability.

D. Workspace and Asset Protection 

InLife Benefits is committed to maintaining a healthy, safe, and secure work environment, ensuring fair working conditions for all employees. Every individual is expected to act responsibly, avoiding behaviors that could compromise health, safety, or environmental sustainability, while actively supporting initiatives to reduce the ecological impact of operations.

E. Safeguarding Assets and Information 

All tangible and intangible assets including real estate, equipment, and supplies must be protected from misuse or damage and utilized strictly for authorized business purposes. Business information acquired in the course of assignments must be treated with the highest level of confidentiality, disclosed only on a need-to-know basis or with explicit authorization. Intellectual property, encompassing ideas, products, methodologies, and strategies, must be preserved and, where appropriate, secured through patents, trademarks, or copyrights. This obligation extends beyond the duration of employment.

F. Data Integrity and Compliance

InLife Benefits records and data must be maintained with accuracy, completeness, and accessibility, in compliance with legal requirements and internal standards. Records, including electronic files and emails, must be retained for the legally mandated period and, in cases of litigation or regulatory review, for as long as necessary. Any fraudulent alteration or falsification of records is strictly prohibited.

G. Personal Information and Privacy

InLife Benefits is committed to the highest standards of data protection, ensuring that personal information is managed responsibly and privacy rights are fully respected. Information relating to customers, employees, suppliers, or other third parties must be accessed strictly on a need-to-know basis and always in compliance with applicable laws.

Personal data may only be collected, processed, and shared for legitimate, clearly defined purposes, and only to the extent necessary. The preferences and privacy choices of data owners must be honored at all times. Special diligence is required when transferring information across national borders, including within Group entities. Employees must confirm applicable legal restrictions before transmitting data and seek guidance from the Compliance Function whenever uncertainty arises.

H. Conflicts of Interest

Employees are expected to act with unwavering commitment to the InLife Benefit’s interests. A conflict of interest arises when personal activities or relationships compromise, or appear to compromise, an employee’s ability to act in the best interest of the organization. Such situations must be avoided wherever possible; if unavoidable, they must be transparently managed to prevent any harm to the Group.

Employees are responsible for remaining vigilant to potential conflicts in their daily business activities and are required to disclose them promptly to their manager or the Compliance Function. In cases of uncertainty, employees must proactively seek guidance to ensure clarity and alignment with the Group’s standards of integrity.

I. Anti-Bribery and Anti-Corruption

InLife Benefits maintains a zero-tolerance stance against bribery and corruption, requiring all employees to conduct business with integrity and in strict adherence to ethical standards. Any form of undue payment, gift, entertainment, or benefit whether offered or received is prohibited, particularly cash, negotiable securities, or equivalent instruments.

Gifts or hospitality may only be exchanged when directly related to legitimate business activities, are customary and appropriate to the circumstances, comply with local laws, and remain modest in value. Given the InLife Benefit’s interactions with public officials, institutions, and representatives, employees must exercise heightened diligence, refraining from offering or accepting anything beyond ordinary business practices. Any gifts or entertainment extended to public officials require prior approval from the Compliance Head.

Employees are obligated to report to their manager or the Compliance Function any attempt to solicit or provide undue benefits that could compromise, or appear to compromise, the integrity of business decisions.

J. Customer Relations 

Customer satisfaction is central to the InLife Benefit’s strategic vision and a cornerstone of its leadership position. Employees are expected to engage with customers honestly, professionally, and transparently, avoiding any conduct that could be misleading or deceptive. Decisions and actions must consistently prioritize the customer’s best interests, with conflicts of interest either avoided or responsibly managed to safeguard those interests.

Products and services must be presented with complete accuracy, supported by factual and truthful information. Accessible and reliable after-sales support is essential, while customer satisfaction must be continuously monitored to identify opportunities for improvement. The development of new products and services must align with evolving customer needs, guided by a clearly defined process and reinforced through periodic strategic planning at the InLife Benefit level.

K. Fair Competition and Antitrust

InLife Benefits affirms the essential role of free and fair competition in driving growth and performance. Our competitive strength must rest on the quality of our products, services, and ethical business practices. Employees are strictly prohibited from discrediting competitors, misrepresenting facts, or engaging in any conduct that distorts the marketplace for improper gain.

All forms of behavior intended to restrict or undermine fair competition are forbidden. Employees must remain vigilant in their interactions with competitors, ensuring full compliance with applicable competition and antitrust laws. Where uncertainty arises, guidance must be sought from the Legal and Compliance Functions to safeguard integrity and adherence to regulatory standards.

L. Supplier Selection

InLife Benefits is committed to ensuring supplier relationships are conducted with fairness, transparency, and integrity. Employees must engage suppliers in a straightforward manner, avoiding any conflicts of interest.

Supplier selection is strictly based on the principles of fair competition and the demonstrated quality of products and services. Evaluations must also consider adherence to ethical standards on labor and human rights, as well as the environmental impact of production and supply practices.

M. Financial Information

InLife Benefits upholds complete and accurate financial reporting as a cornerstone for enabling stakeholders to make informed decisions. All financial reports must be truthful, fair, comprehensive, and fully compliant with both InLife Benefits policies and applicable accounting standards.

Employees are required to handle financial data with integrity, ensuring accuracy, transparency, and proper retention in recoverable formats throughout the mandated period. Any fraudulent alteration or falsification of records is strictly prohibited and cannot be justified under any circumstance.

Managers bear the responsibility of fostering a strong culture of internal control over financial reporting. Financial statements and disclosures provided to shareholders, regulators, and the public must be clear, accessible, and compliant with local legal requirements, reinforcing trust and accountability across all stakeholder relationships.

N. Insider Dealing

InLife Benefits enforces strict measures to prevent the misuse of inside information and to safeguard the integrity of securities transactions. Inside information defined as non-public, specific information that could materially affect the value of securities if disclosed must always be handled with the highest level of confidentiality and shared only on a need-to-know basis in compliance with applicable laws.

Employees in possession of such information are prohibited from disclosing it beyond colleagues with a legitimate business reason or authorized third parties (e.g., auditors, lawyers, consultants) bound by confidentiality agreements. They must not trade, directly or indirectly, nor provide tips or recommendations based on inside information, whether for personal gain or on behalf of the Group.

Any employee intending to trade or advise on Group securities must ensure full compliance with all relevant laws, regulations, and internal policies, thereby upholding the Group’s commitment to ethical conduct and market fairness.

O. Communicating with External Parties

InLife Benefits is committed to transparency in financial markets and ensures that communications with the media, analysts, investors, and the public are managed with precision and care. All stakeholder communications must be clear, timely, and accurate, reinforcing trust and credibility.

Engagements with external parties including media, financial analysts, rating agencies, investors, and authorities are strictly handled by designated functions. Employees are prohibited from disclosing information or documents about the InLife Benefits unless expressly authorized. Furthermore, employees must refrain from commenting publicly on market rumors or speculation unless validated by official sources.

P. Anti-Money Laundering, Counter-Terrorist Financing, and International Sanctions

InLife Benefits is unwavering in its commitment against money laundering and terrorist financing, ensuring strict compliance with applicable sanctions laws and regulations. Any conduct that could be construed as supporting financial crime is categorically prohibited.

Employees with relevant responsibilities must maintain thorough knowledge of customers and transactions in line with InLife Benefits Standards and local legislation. Whenever there is suspicion that a counterparty may be misusing the InLife Benefit’s products or services for illicit purposes, employees are required to immediately notify the Compliance Function or the Money Laundering Reporting Officer.

III. FINAL PROVISIONS

A. Adoption and Distribution

The Code of Conduct has been formally approved by the Board of Directors of InLife Benefits. Chief Executive Officers are accountable for ensuring its effective implementation, together with the accompanying regulations, in full compliance with local legal requirements.

This Code of Conduct supersedes any prior codes of conduct within InLife Benefits, and all internal policies must align with its provisions. Any conflicts between the Code of Conduct, implementing regulations, and local legislation must be promptly escalated to InLife Benefit’s Compliance for resolution. InLife Benefit’s Compliance also holds responsibility for recommending updates to the Board to ensure the Code of Conduct remains current and relevant.

B. Training and Awareness

To secure proper understanding and consistent enforcement, mandatory introductory and annual refresher compliance training programs are established. CEOs play a pivotal role in promoting broad awareness of the Code of Conduct and its implementing regulations, ensuring active participation of all employees. Each employee must be provided with a copy of the Code, reinforcing accountability and alignment across the organization.