Group Code of Ethics and Conduct Summary

As part of QBE’s commitment to ethics and compliance, QBE’s Group Code of Ethics and Conduct (“Code”) sets global minimum standards which may be supplemented by local policies that address specific requirements and laws. The Code applies to all employees, directors, contractors, contingent workers, agents, joint ventures controlled by QBE and anyone else who represents QBE in any capacity. QBE believes everyone has the right to a fair and inclusive working environment and everyone is responsible for fostering a working environment where everyone is treated with dignity, courtesy and respect and which is free from all forms of unlawful behaviours.

Because the Code is critical in defining and guiding everyone’s behaviours, it is mandatory for everyone at QBE. At QBE, we expect everyone to behave in a professional and courteous manner, both internally and externally. QBE takes a no tolerance approach to behaviour that is harassing, threatening, inappropriate, offensive or abusive, bullying or intimidating. We all have a responsibility in ensuring a safe, respectful and inclusive environment which is part of QBE DNA. QBE is also committed to diversity and inclusion in all its business practices and strives to ensure QBE is an equal opportunity employer.

All QBE employees are expected to act lawfully, with integrity and work in a manner that is consistent with the spirit, intent and requirements of the Code and are expected to use good judgement and speak up when they have questions or concerns. QBE employees are encouraged to raise and report their concerns promptly and without delay to their manager, local compliance team or via the QBE Ethics Hotline.

QBE employees are also required to complete all mandatory training assigned and always act in a positive, respectful and professional manner.