The Pan-American Life Insurance Group and all of its subsidiaries and affiliates herein referred to collectively as "the Company", have a long-standing reputation of acting in a legal and ethical manner. This Corporate Code of Conduct & Ethics (Code) is meant to summarize and clarify expectations related to appropriate conduct for our directors, officers and employees around the world. The Code is also designed to deter wrongdoing by promoting:
- Honest and ethical conduct;
- Avoidance of conflicts of interest, including disclosure to an appropriate person or persons identified in the Code of any material transaction or relationship that reasonably could be expected to give rise to such a conflict;
- Full, fair, accurate, and understandable disclosure in reports and other public communications made by the Company;
- Safeguarding and proper handling of our customer's private information and other confidential information;
- Prompt internal reporting of suspected Code violations to an appropriate person or persons; and
- Accountability for adherence to the Code.
The Code does not address every possible legal and ethical issue that may arise. Ultimately, we must rely on each person's character and good sense of right and wrong. If you have an issue that you are not sure about, please seek guidance from others in the Company.
This Code applies to directors, officers and employees of the Company wherever they may be located. Additionally, we expect non-employees, such as our vendors and distributors, who are representing us to follow similar high ethical business practice standards.
Failure to follow the Code will result in disciplinary action up to and including termination of employment or relationship with the Company.
We follow all compliance-related directives and requirements in all jurisdictions around the world where we do business. In many situations, the Company's standards exceed what is legally required.