American International : AIG Employee Code of Conduct

Published: 2025-03-17 15:18:04 ET AIG

Code of Conduct

PURPOSE & VALUES

Our Purpose is to discover new potential by reimagining what AIG can do for you.

Our Values and how we bring them to life:

TAKE OWNERSHIP

SET THE STANDARD

WIN TOGETHER

BE AN ALLY

DO WHAT'S RIGHT

2 AIG - Code of Conduct

Table of Contents

A Message from our Chief Executive Officer

A Message from our Chief Compliance Officer

Delivering on Our Commitments

Why Do We Have a Code?

To Whom Does the Code Apply?

Individual Responsibilities

Additional Responsibilities for Managers

Asking Questions & Raising Concerns

Non-Retaliation Policy

Corrective Action

Waivers of the Code

Our Commitments to Each Other

AIG Talent

Respecting Others

Respecting Human Rights

A Work Environment Free from

Harassment and Intimidation

Safe, Healthy and Secure Workplace

Alcohol and Drug Use

Employee Privacy

Our Commitments in the Marketplace

Customer Privacy and Data Security

Conflicts of Interest

Corporate Opportunities

Personal Relationships

Outside Activities

Gifts and Entertainment

Gifts and Entertainment to Government Officials

Relationships with Our Business Partners

Supplier Diversity

Fair Dealing

Antitrust and Fair Competition

Competitive Information

Our Commitments to Our Shareholders

Financial and Tax Reporting

Accurate Business Records

Records Management

Safeguarding AIG Resources

Physical Property

Personal Security

Travel Security

Intellectual Property

Proprietary Information/

Trade Secrets/Confidential Information

Funds

AIG Technology Resources

Our Commitments as Corporate Citizens

Sustainability

Global Corporate Citizenship

Political Activities

Trading in Securities

Money Laundering Prevention

Economic Sanctions, Anti-boycott,

and Export Control Laws

Communicating with the Public

Communicating with Regulators

and Other Government Officials

Social Media

Government Business

Anti-Corruption and Bribery

When used in this Code of Conduct, 'AIG' refers to American International Group, Inc. and its subsidiaries worldwide. Business units and jurisdictions may have other codes consistent with or more stringent than this Code of Conduct. These codes may impose additional responsibilities on employees in those business units and jurisdictions. Concerns regarding potential conflicts between a provision of this Code of Conduct and local laws should be escalated to the compliance officer.

3 AIG - Code of Conduct

A Message from Our Chairman & Chief Executive Officer

Dear colleagues,

Operating with ethics and integrity is a primary focus of everything we do at AIG, which is why our Code of Conduct is critically important. Always doing the right thing and maintaining a safe environment for colleagues to raise concerns is paramount to earning and preserving the trust of our stakeholders.

AIG's Purpose and Values statement guides how we act as a company and as individuals. At its core, the statement is centered around Discovering New Potential and Reimagining what AIG can do for you. Our Values-Win Together, Take Ownership, Set the Standard, Do What's Right and Be an Ally-set clear expectations for what it means to work at AIG and encourage the behaviors required to drive change and long-term success.

The AIG Code of Conduct outlines standards and policies that apply to all colleagues and provides guidelines about how we work with each other, as well as with our customers, distribution partners, regulators and other stakeholders.

This Code, along with your very good judgment and decision making, will guide your actions.

As we work to create the AIG of the future, thank you for your commitment to upholding our Values and the highest levels of ethics and integrity.

Peter Zaffino

Chairman & Chief Executive Officer

A Message from Our Global Chief Compliance Officer

Dear colleagues,

The AIG Code of Conduct contains the rules and guidelines that each of us should keep in mind as we engage in our daily activities.

The Code of Conduct reflects AIG's Purpose and Values and outlines the laws and regulations by which we as a corporation are governed. By complying with these standards, we uphold AIG's reputation for transparency and foster a culture of ethics and integrity.

This Code of Conduct is designed to help you do what's right. While it provides guidance for most situations, it is not an all-encompassing resource. If you have questions related to a specific situation, business or corporate group that may be unclear, please reach out to your manager,

HR business partner or Compliance Officer. Also, please speak up if you notice something that does not appear to align with the principles outlined in the Code.

Thank you for continuing to uphold AIG's strong culture of excellence and for your continued adherence with AIG's Code of Conduct. Our efforts create trust and give our customers, distribution partners, regulators, and other stakeholders confidence in the strength and reliability of AIG.

Karen J. Nelson

Senior Vice President

Global Chief Compliance Officer

4 AIG - Code of Conduct

Delivering on Our Commitments

At the core of AIG's business is a promise that we will stand behind our products and services. Personal and organizational integrity are critical to delivering on this promise and protecting our reputation.

Delivering on our commitments is vitally important to our employees, customers, distribution and other business partners, regulators, shareholders, and the communities in which we live and do business.

5 AIG - Code of Conduct

Delivering on Our Commitments

Why Do We Have a Code?

The AIG Code of Conduct (the "Code") provides ethical guidelines for conducting business across AIG. The Code is a resource for all AIG officers and emplyees. This Code cannot address every issue that we may encounter, but it does provide guidance and resources for those times when the right choice is not clear. Additional information, including relevant rules and policies, may be found in links throughout this document as well as in our corporate policies.

This Code is organized based on the commitments we deliver to each of the following groups:

•

Our fellow employees trust us to value and respect them.

•

Our customers and our distribution and business partners

trust our integrity.

•

Our regulators expect us to be transparent and act

with integrity.

•

Our shareholders trust our stewardship.

•

Communities around the world rely on us to be responsible

corporate citizens.

To Whom Does the Code Apply?

The Code applies to all AIG officers and employees. Certain AIG business partners, such as agents and consultants, who represent AIG to the public are also expected to adhere to the intent of the Code, as well as to applicable provisions of the AIG Third Party Code of Conduct, the AIG Supplier Code of Conduct and any contractual commitments, when working on behalf of AIG companies.

AIG is a large organization, and yet we are united by our commitment to deliver on our promises. Each of us has a responsibility to earn and uphold the trust that is placed in us.

The most current version of the Code can be accessed on AIG's Corporate Governancewebsite. The Code may be amended from time to time; such amendments will become effective immediately upon posting.

6 AIG - Code of Conduct

Delivering on Our Commitments

Individual Responsibilities

Meeting our responsibilities enables our business to succeed and grow, today and in the future. Each of us is expected to:

•

Understand and act in accordance with this Code, AIG's

policies, and applicable laws and regulations.

•

Seek guidance from management, compliance personnel or

AIG's legal counsel when you have questions.

•

Promptly report concerns about possible violations of this

Code, AIG's policies or applicable laws and regulations to

management or to one of the resources listed on the

next page.

•

Participate in ethics and compliance training to keep up to

date on current standards and expectations.

•

Fully cooperate with any internal investigations.

No reason, including the desire to meet business goals, can ever be an excuse for violating this Code, AIG policies, laws, or regulations.

Additional Responsibilities for Managers

Each manager is expected to fulfill the following additional responsibilities:

•

Serve as a role model by demonstrating the highest ethical

standards and create and sustain a culture of trust, honesty,

integrity and respect.

•

Be a resource for employees. Ensure that they are aware of,

understand, and know how to apply this Code, AIG's policies

and applicable laws and regulations in their daily work.

•

Make yourself available to employees to present issues,

complaints or grievances in a safe and secure environment

and reinforce AIG's non-retaliation policy. Ensure such matters

are addressed in a fair and timely manner.

•

Seek assistance from other managers or AIG's legal counsel,

compliance officers or human resource professionals when

unsure of the appropriate response to any given situation or

report it through the AIG Compliance Help Line.

•

Be proactive. Take reasonable actions to prevent and identify

misconduct. Report situations that might impact the ability of

employees to act ethically on behalf of AIG.

The Headline Test

For Making Better Decisions

Contact

Legal or

UNSURE

Is it legal?

Compliance

YES

Is it consistent with AIG's

UNSURE

values and policies?

YES

Do Not

Contact

Proceed

Your

Manager,

UNSURE

Is it appropriate

HR, Legal or

Compliance

and honest?

YES

Would I want my

UNSURE

coworkers, friends,

family or the public to

read about this

in the news?

YES

Your decision appears to comply

with the Code.

If you have any further questions, you can

always reach out to your manager,

HR, Legal or Compliance.

7 AIG - Code of Conduct

Delivering on Our Commitments

Asking Questions & Raising Concerns

Most concerns likely to be faced at work can be resolved by talking to and working with management, Human Resources, Employee Relations or your designated compliance officer. In addition, employees may ask questions, raise concerns or report instances of non- compliance with this Code, AIG policies, or applicable laws and regulations by contacting any of the following:

•

AIG's Global Compliance Group at + 1 646 857-1877or [email protected].

•

AIG Compliance Help Line at + 1 877 244-2210, online at www.aigcompliancehelpline.com, or scan the QR code below, subject

to local laws. The Compliance Help Line is staffed by an independent third party that provides written reports to AlG's Global

Compliance Group. Communications to the Help Line may be made anonymously, subject to local laws, and may be made in all

major languages.

For concerns related to accounting, internal accounting controls or auditing matters, employees may contact either of the above (anonymously through the Help Line, subject to local laws) or may bring the concern to the attention of the Chair of the Audit Committee of AIG's Board of Directors by email at [email protected] in writing to: Chairman of the Audit Committee, American International Group, Inc., 1271 Ave of the Americas, Floor 41, New York, NY 10020-1304.

AIG COMPLIANCE HELP LINE

The help line is operated by an independent third-party service provider, who will forward reports to AIG's Global Compliance Group. Communications may be made anonymously, subject to local laws.

Phone

Web

QR Code

+1 877 244-2210

aigcompliance

helpline.com

Global Compliance Group Assesses Report

Seeking Advice

Report a Concern

Guidance will be provided to

Matter will be promptly investigated

make the right decision.

by the appropriate internal

organization within AIG.

8 AIG - Code of Conduct

Delivering on Our Commitments

Q&A

Asking Questions and Raising Concerns

Q: What happens when I make a report to the AIG Compliance Help Line?

A: After taking the call, an outside service provider will forward a report to AIG's Global Compliance Group. If the report is submitted online, the outside service provider will send the report directly to the Global Compliance Group.

1. If you request advice, you will be contacted about the issue and provided with guidance and interpretation so that you can make the right decision.

2. If you want to report a suspected violation, the outside service provider will take down any relevant information and will forward a report to the Global Compliance Group. Any reports regarding questionable accounting, internal accounting controls, and auditing matters will be reviewed with representatives of the Global Investigations Group and then, if necessary, reported to the Audit Committee of the AIG Board of Directors.

3. If the matter would be more appropriately addressed by another internal organization within AIG (e.g., Legal, Internal Audit, Global Security or Human Resources), the Global Compliance Group may send the report to that organization for handling.

A: AIG encourages employees making reports to identify themselves so that the information can be investigated promptly and thoroughly. Our ability to directly contact an employee who has raised a concern will expedite any investigation. However, subject to local law or labor agreement, you may choose to remain anonymous when reporting a matter to the AIG Compliance Help Line.

A: Every reasonable effort will be made, consistent with law and AIG policy, to maintain the confidentiality of any employee who reports a violation or suspected violation in good faith. AIG prohibits retaliation against any employee for making a good faith report of actual or suspected violations of this Code, other AIG policy, or applicable laws or regulations. Violation of this non-retaliation policy may result in corrective action, up to and including termination.

9 AIG - Code of Conduct

Delivering on Our Commitments

Non-Retaliation Policy

AIG prohibits retaliation against any employee for making a good faith report of actual or suspected violations of this Code, other AIG policy, or applicable laws or regulations, and violation of this non-retaliation policy may result in corrective action, up to and including termination.

Corrective Action

Violating this Code, other AIG policy, or applicable laws or regulations, or encouraging others to do so, puts AIG's reputation at risk and therefore may result in corrective action. Failing to promptly report known violations by others also may be a violation of this Code. Corrective action may include coaching, verbal or written warning, termination of employment and loss of employment-related benefits.

Waivers of the Code

From time to time, AIG may amend or waive certain provisions of this Code. Any employee who believes that a waiver may be appropriate should discuss the matter with their designated compliance officer. Only the AIG Board of Directors or its Nominating and Corporate Governance Committee may grant a waiver of a specific provision of the Code for an executive officer of AIG.

10 AIG - Code of Conduct

Disclaimer

AIG - American International Group Inc. published this content on March 17, 2025, and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on March 17, 2025 at 19:17:05.951.