Third Party Code of Conduct

Last updated March 20, 2020

CopperPoint Insurance Companies which includes CopperPoint Insurance Company, Pacific Compensation Insurance Company, Alaska National Insurance Company and their affiliated companies (“CopperPoint)” is committed to conducting its business in accordance with the highest ethical standards. This Third-Party Code of Conduct outlines our commitment to ethical business practices and compliance with all applicable laws. CopperPoint expects all suppliers, vendors, subcontractors, agents, and consultants (referred to here as “you”) acting on CopperPoint's behalf or, with whom it does business, to share these values and adhere this Third-Party Code of Conduct.

  • Conduct business ethically and with integrity. CopperPoint expects you to share its commitment to conducting business with the highest ethical standards, treating employees, customers, policyholders, and business partners with fairness, dignity, and respect.
  • Comply with all laws. CopperPoint expects you to conduct business in full compliance with all applicable laws and regulations, including, but not limited to, compliance with all applicable U.S. and international economic sanctions and export control laws and regulations, all applicable U.S. and international antitrust and competition laws and regulations, and detection, prevention, and reporting of potential money laundering and terrorist financing activities, applicable U.S. and international anti-corruption laws, including the United States Foreign Corrupt Practices Act, and all other applicable laws that prohibit corruption, extortion, kickbacks, or bribery, including the U.K. Bribery Act 2010. You are expected to comply with all applicable laws when dealing with the government and to act with integrity with respect to government officials.
  • Keep Confidential Information from unauthorized access, use and disclosure. The protection of confidential and sensitive company information and that of our policyholders, customers, employees, and business partners is of the utmost importance. CopperPoint expects you to maintain appropriate administrative and technical security procedures and controls to safeguard this information on our behalf. CopperPoint also expects you to comply with all applicable U.S. state and federal laws and international privacy and data protection laws and regulations, including laws and regulations regarding the cross-border transfer of personal information. CopperPoint expects you to protect the intellectual property ("IP") of CopperPoint, its business partners, and other third parties.
  • Antidiscrimination. CopperPoint supports a culture of nondiscrimination, extending to all of those with whom CopperPoint does business. CopperPoint respects its people, its policyholders, its business partners, and its prospective business partners and deals with each from an overriding sense of fairness, free from unlawful discrimination. You are expected to show a similar commitment. No form of harassment or discrimination on the basis of any legally protected classification or status will be tolerated. CopperPoint expects you to provide goods and/or services without regard to race, color, religion, sex, national origin, age, pregnancy, Veteran status, sexual orientation, gender identity, disability, or any other classifications or status protected by law.
  • Maintain a safe working environment. CopperPoint is committed to maintaining and supporting safe working environments for its employees, tenants, its customers, the public, and third parties with whom it does business. We expect you to adhere to sound occupational health, safety, hazard prevention, emergency preparedness and response procedures and sound business continuity practices. CopperPoint has a zero tolerance for workplace violence, and you are expected to act to prevent workplace violence.
  • Avoid conflicts of interest. CopperPoint desires to preserve and protect its reputation and avoid the appearance of impropriety. CopperPoint expects you to avoid actual or potential conflicts between your business, financial, or personal interests and the interests of CopperPoint. You shall not knowingly deal directly with a CopperPoint employee if you or your family member or relative, including spouse or domestic partner, has a financial interest in our business, unless written approval has been given by CopperPoint's Chief Compliance Officer. Business transactions with CopperPoint, its employees, vendors, contractors, and other third parties shall be transacted free from offers or solicitation of gifts and favors or other improper inducements in exchange for influence or assistance in a transaction. You are expected to act in compliance with CopperPoint's gift restrictions. You shall not seek to gain any advantage through the improper use of payments, business courtesies, gifts, or other inducements.
  • Maintain records that are accurate. CopperPoint expects that you create and retain records in an honest and accurate manner and in compliance with all applicable legal and regulatory retention requirements.

Failure to Comply
In the event that you do not comply with the standards set forth in this Third-Party Code of Conduct, CopperPoint may endeavor to terminate any pending purchase order or contract with without any liability to CopperPoint, and without prejudice to any other rights of CopperPoint.

Reporting Violations
If you suspect or become aware of any violation of this Third-Party Code of Conduct, by anyone, including a CopperPoint employee, contact CopperPoint's General Counsel and Chief Compliance Officer, Sara Begley at sbegley@copperpoint.com.

You may also report violations through the CopperPoint Ethics Hotline at 1.800.826.6762 or at copperpoint.alertline.com. You may report anonymously.