ENTERPRISE CODE OF CONDUCT & BUSINESS ETHICS ® ETHICSLINE 1-877-772-6326 EXECUTIVE LEADERSHIP CONTACT INFORMATION A MESSAGE FROM LEADERSHIP SENIOR AND OPERATING COMPANY LEADERSHIP TEAM Dear Colleague: JACK SALZWEDEL BILL WESTRATE People often ask us what makes our Enterprise, the American Family Insurance Mutual Chairman and President Holding Company, so special. That’s easy. It’s you, our people – dedicated, innovative Chief Executive O cer and customer-focused. You not only care about what you do, but also how you do it … American Family Mutual Paula O’Neil with integrity. Insurance Group Exec. Admin. Assistant (608) 242-4100 x31252 In simple terms, integrity means avoiding conflicts of interest, following local, state and Cynthia Koeller EXECUTIVE LEADERSHIP CONTACT INFORMATIONExec. Assistant to CEO federal laws, and living by the values our Enterprise and companies have established. (608) 242-4100 x31424 But integrity goes far beyond just knowing and complying with the rules. It’s about JACK SALZWEDEL SENIOR AND OPERATING COMPANY LEADERSHIPChair and Chief Executive TEAM Officer doing the right thing even when no one is watching – or there’s no specific rule about it. GERRY BENUSA FABIAN FONDRIEST It’s about not cutting ethical corners or taking shortcuts. And, it requires identifying and acting on problems, not ignoring them. Chief Sales O cer President, Homesite and JACK SALZWEDEL BILL WESTRATE American Family Direct Sue Coyle Take the time to review our Enterprise Code of Conduct andChairman Business and Ethics. It applies to President Chief Executive O cer Admin. Sr. Assistant Karen Walnut all companies that are part of the American Family Insurance Mutual Holding Company. (608) 242-4100 x30860 Assistant to Fabian Fondriest Paula O’Neil (See the listing on page 2.) American Family Mutual (617) 832-1341 Insurance Group Exec. Admin. Assistant (608) 242-4100 x31252 Our Enterprise has grown and diversified significantly inCynthia recent Koelleryears. We’ve welcomed new companies, including several not directly involved inExec. insurance Assistant but thatto CEO contribute to our success in other valuable and differentiating ways.(608) Together, 242-4100 we all x31424 share an JOHN HOLLAR DAVID HOLMAN uncompromising commitment to integrity and ethical behavior. BILL WESTRATE President President and Chief Operating Chief Strategy O cer/ This Code provides direction and examples to address theGERRY most common BENUSA ethical issues FABIANO cer The FONDRIEST General Secretary you may face during your work. But we also know our world is constantly changing – Chief Sales O cer President,Sherry Humphres Homesite and Mary Greenberg and with those changes may arise new ethical challenges not addressed in the Code. If AmericanExecutive AssistantFamily Direct to CEO & Exec. Admin. Assistant you face one of those situations or suspect ethical misconduct,Sue Coyle speak up. Inform your manager or contact the appropriate resourceCorporate Travel Manager (608) 242-4100 x30608 Admin. Sr. Assistant for your company, listed on page 17. Karen(615) 744-1461 Walnut (608) 242-4100 x30860 Assistant to Fabian Fondriest (617) 832-1341 You can also report suspected ethical misconduct to our Enterprise EthicsLine at 1-877-772-6326. The EthicsLine is operated by a third party. You can also report information to the EthicsLine anonymously if you’d like. DANIEL KELLY KRISTIN KIRKCONNELL As individuals and as an Enterprise, we can’t take exemplary behavior for granted. That starts with reading and understandingChief Financial O cer/ Chief Information O cer this Code. It continues with remaining vigilant by actingJOHN ethically HOLLAR and reporting situations when that may not be the case. DAVIDTreasurer HOLMAN Dawn Robertson President and Chief Operating Chief Strategy O cer/ Thank you for making our Enterprise special, and for living our commitment to ethics and integrity every day. Vicki Josephson Admin. Sr. Assistant O cer The General SecretaryAdmin. Sr. Assistant (608) 242-4100 x36342 (608) 242-4100 x32934 Sherry Humphres Mary Greenberg Executive Assistant to CEO & Exec. Admin. Assistant ETHICSLINE 1-877-772-6326 Corporate Travel Manager (608) 242-4100 x30608 (615) 744-1461 DANIEL KELLY KRISTIN KIRKCONNELL Chief Financial O cer/ Chief Information O cer Treasurer Dawn Robertson Vicki Josephson Admin. Sr. Assistant Admin. Sr. Assistant (608) 242-4100 x36342 (608) 242-4100 x32934 OPERATING COMPANY HEADQUARTERS American Family Insurance Main Street America Madison, Wisconsin Jacksonville, Florida Homesite Boston, Massachusetts The General Nashville, Tennessee Networked Insights and Moonrise HomeGauge Chicago, Illinois Asheville, North Carolina 1 ETHICSLINE 1-877-772-6326 AMERICAN FAMILY INSURANCE FAMILY OF COMPANIES Founding: 1927 Founding: 2001 Headquarters: Madison, Wisconsin Headquarters: Asheville, North Carolina American Family Insurance inspires, protects and restores dreams by HomeGauge is a leading provider of inspection software and business providing exceptional multi-line products and service. Our exclusive agents services primarily for the home inspection industry. The home sell American Family-brand products and serve as trusted advisers for inspection is a crucial touchpoint with home buyers on their journey to customers in 19 states. We meet needs of customers who want to purchase homeownership and HomeGauge aims to provide the best experience for home buyers as they interact with their reports. insurance through other channels with products offered by our American Family Connect platform. Founding: 2006 Headquarters: Chicago, Illinois Founding: 1963 Networked Insights helps brands answer interesting questions about Headquarters: Nashville, Tennessee their audiences. We use our custom and predictive audience data, and Permanent General Companies, Inc. (PGC), operating under The our audience research capabilities to help solve real problems that General® brand, offers a range of products designed to meet the unique others cannot. Many clients use our data to activate our audiences in needs of the non-standard auto insurance customer. We write business digital and offline, delivering outstanding results. through multiple distribution channels in 47 states with a vision of “making life easier” for our customers. Founding: 2017 Headquarters: Chicago, Illinois ® Founding: 1997 Moonrise is an on-demand jobs platform that connects hard-working, Headquarters: Boston, Massachusetts motivated, and qualified people in search of extra income with Homesite was one of the first companies to enable customers to reputable employers in need of filling short-term shifts. We’re here to purchase home insurance online, during a single visit. And, we help people fulfill the dream of financial stability. continue to innovate and grow to meet needs of consumers, partners and employees. Today, Homesite offers insurance coverage for home, renters, condo, small business, term life, and flood. Founding: 1923 Headquarters: Jacksonville, Florida The Main Street America Group offers a wide range of commercial and personal insurance, as well as fidelity and surety bond products, to individuals, families and businesses throughout the United States. Through eight carriers, we offer our products exclusively through independent agents who find policyholders the best combination of coverage, price and service. ETHICSLINE 1-877-772-6326 2 INTRODUCTION The Enterprise Code of Conduct and Business Ethics guides our daily WHO THE CODE APPLIES TO business activities to ensure we operate within ethical and legal This Code applies to American Family Insurance Mutual Holding standards. It is also important to remember that, along with the Code, Company and its direct or indirect operating companies and affiliates each company has policies and is subject to laws and regulations that (the “Enterprise”) and the Board of Directors, officers, and employees of ensure we make sound workplace decisions. It is important to stay such entities. The Code also applies to contingent workers and interns current with company policies and applicable laws and regulations as while performing services on behalf of the Enterprise. they may change periodically. DEFINTIONS Code: Refers to the Enterprise Code of Conduct & Business Ethics. Colleagues: Refers to all employees, as well as, all associates, contingent workers, and any other temporary workers. This excludes all agents and agency staff. Company: Refers to the entity with whom you are employed or provide services for unless otherwise indicated. RESOURCES Each company has resources to help you with your Code questions. The appropriate resource for your company can be found on Page 17 of the Code. TABLE OF CONTENTS Integrity: The Code’s Foundation .............................................4 Outside Interests ......................................................................10 The Basic Blueprint ......................................................................4 Conflict of Interest .....................................................................10 Issues Beyond the Code ...............................................................5 Gifts, Meals and Entertainment .................................................11 Reporting and Investigations ......................................................5 Political Activities ......................................................................13 No Retaliation ..............................................................................6 Other Laws and Regulations ...................................................14