Global Standards of Business Conduct

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Arthur J. Gallagher & Co.

Global Standards of Business Conduct

Leading with Integrity The Gallagher Way

The Global Standards of Business Conduct explain our most important legal and compliance obligations. They also describe the Shared Values that motivate our decision-making and guide our actions every day.

We are each accountable for understanding and following the laws, policies, rules and regulations that impact our jobs and the company. As a global insurance brokerage and risk management firm, we are subject to numerous laws, rules and regulations established by the various countries in which we do business. Because we are a global company, your job may be affected by laws of countries other than the one where you work.

We are each also responsible for understanding and living the Shared Values that are the foundation of our company. By following both the letter and spirit of applicable laws and our Shared Values, we help to protect our clients and our company and build our reputation for integrity.

The Global Standards apply to all Gallagher directors, officers and employees. We expect Gallagher Global Alliance members, strategic vendors, suppliers and other business partners or agents acting on our behalf to adhere to similar high standards of behavior. Of course, no single document can address every situation—rather, these standards should act as a guide in helping you understand the right thing to do in a variety of situations. Some business units within Gallagher may have stricter standards due to local laws or particular business requirements. If you ever need clarification about how a law or regulation could impact your job, or face an ethical dilemma, discuss it with your manager or one of the other resources listed within the Global Standards. The Global Standards are not meant to replace thoughtful behavior and individual good judgment.

On March 4, 2019, we made certain amendments to the Global Standards. Our Board of Directors approved these amendments as part of Gallagher’s continued effort to highlight our commitment to integrity and provide enhanced ethics and compliance resources for our directors, officers and employees. Key amendments to the Global Standards include: expansion of the sections on data privacy for both employees and clients, including an increased emphasis on how to report potential data security incidents and the importance of doing so; updates to the sections on compliance with sanctions and corruption laws; changes to the section on conflicts of interest to highlight the importance of promptly reporting actual or potential conflicts; amendments that clarify and strengthen our gifts and entertainment policy; the addition of examples of red flags and resources to aid in the prevention, detection and reporting of fraud; and clarification of our policies around political activities. This description of the amendments to the Global Standards does not purport to be complete and is qualified in its entirety by reference to the full text of the Global Standards.

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