Quilter : Code of Conduct

Contents

CEO's foreword ___________________________________________________ 3

Introduction _____________________________________________________ 4

Applying this code ________________________________________________ 4

Speaking up ______________________________________________________ 4

Doing business the right way _______________________________________ 5

• i) Acting with integrity and respect

• ii) Treating customers fairly

• iii) Managing conflicts of interest

• iv) Good market conduct

• v) Information, data and communications

• vi) Responsible use of company assets

• vii) Managing the risk of financial crime

• viii) Working with regulators and governments

Regulatory expectations ___________________________________________ 7

Monitoring and reviewing this Code ________________________________ 8

CEO's foreword

Quilter helps to create prosperity for the generations of today and tomorrow and staying true to our values helps us do this in a responsible way.

Our three core values define the character of Quilter:

• - Pioneering: Leading change and driving growth from the front, positively challenging industry convention to create new and rewarding opportunities for our customers and colleagues.

• - Dependable: Using our expertise, care and judgement to guide us and our customers through complex and challenging times, being determined to take people to a better place in their financial future.

• - Stronger together: Using our diversity and our relationships - learning from each other - to create one business with better opportunities for our people and better outcomes for our customers.

Acting in the right way is simply the way we do business. This means we must always act honestly and with integrity to ensure that we're trusted by our customers, colleagues, business partners and the communities in which we work.

Please take time to read and understand this Code as it sets out how all of us can demonstrate our values, respect each other, protect our customers and the trust they place in us, and ensure responsible long-term growth of the business. You are asked to confirm your acceptance of and adherence to this Code each year.

We are all personally responsible for applying these standards and if you have concerns about compliance with this Code, company policies or the law please speak up. No one will be criticised for any loss of business resulting from adhering to this Code, similarly no one will be prejudiced by reporting concerns in good faith in relation to compliance with the expected standards.

Thank you.

Steven Levin CEO, Quilter plc

1. Introduction

Doing business the right way means acting with integrity and staying true to our values to ensure we earn the trust of our customers, colleagues, shareholders, business partners, and the communities in which we work. This Code provides a guide on the standards we're all expected to maintain and signposts where you can find more information. Guidance is provided on the most common issues you may face, however, where a situation or dilemma arises that isn't covered in the Code it's useful to consider the situation from other perspectives. For example, ask yourself what would our customers think about a particular action? How would the regulator react? What would happen if it was reported in the media? Would you feel proud of your actions? If you're in any doubt you should speak to your line manager or Risk & Compliance for advice before you act.

2. Applying this Code

Everyone at Quilter is expected to demonstrate the highest standards of personal and business integrity and must adhere to the requirements of this Code, all applicable laws and regulations and other company policies. Quilter operates through a number of regulated entities, principally in the UK but also in some overseas territories. Where differences exist between the requirements of this Code and local laws, we should follow the higher, more stringent rule or standard.

3. Speaking up

At Quilter we want to promote a culture of 'speaking up' where people feel able to raise any concerns they may have about misconduct, malpractice, or wrongdoing. If you see behaviour or action that you believe conflicts with the law, our values or this Code you have a responsibility to speak up and share your concerns, which you can do without the fear of repercussion. In the first instance you should raise concerns or queries with your line manager or via HR. There may however be instances when you're not comfortable with this, or it is not possible or appropriate. In these cases you can report genuine concerns confidentially and anonymously via the independent Whistleblowing Ethics Hotline. This is available 24hrs, 365 days of the year (contact details are provided at the back of this Code). The information given via the Ethics Hotline will be passed on anonymously to senior executives of Quilter who will act on it whilst protecting the information provider. All whistleblowing reports are treated confidentially, seriously and are fully investigated.

Colleagues can access more information on this via our Whistleblowing Policy available on our internal intranet page.

4. Doing business the right way

i) Always acting with integrity and respect

Everyone at Quilter is expected to act with the highest standards of integrity, honesty and ethics at all times. We must comply with applicable laws and regulations, this Code and other company policies and standards. Our working relationships should be based on fairness, respect, honesty and collaboration. That means we have zero tolerance of any form of harassment, abuse, discrimination or bullying of colleagues, contractors, suppliers, or anyone we deal with. All colleagues should behave in a way that supports an inclusive culture, embracing all forms of diversity. This applies during our daily business activities and also when we are in the communities in which we work. We respect human rights and reject any form of modern slavery and we are an accredited National Living Wage employer in the UK.

More information about our inclusion and diversity action plan can be found our website.

ii) Treating Customers Fairly

We have a duty to act with due care, skill and diligence to ensure that we treat all customers fairly. That means our products and services are appropriate to meet the needs of our customers and we provide information which is accessible, clear, fair and not misleading. We should ensure that no customer or group of customers is treated favourably at the detriment of other customers. Where customer claims and complaints arise we deal with these in an independent, timely and efficient manner.

The Financial Conduct Authority (FCA) has confirmed that a new Consumer Duty, will come into force during 2023. The Duty is intended to improve how firms serve consumers. It sets higher and clearer standards of consumer protection across financial services and requires firms to put their customers' needs first. The Duty is made up of an overarching principle and new rules firms will have to follow. It will mean that consumers should receive communications they can understand, products and services that meet their needs and offer fair value, and they get the customer support they need, when they need it. This Code of Conduct will be updated to reflect the new Consumer Duty closer to the time it comes into force, in the summer.

Colleagues can access more information on this via our Customer Policy available on the internal intranet page.

iii) Managing conflicts of interest

A conflict of interest may arise between Quilter and its colleagues, customers or suppliers, or between different businesses within Quilter. These conflicting interests could lead to behaviours, actions and decisions which are improper, unethical or not impartial. Ideally we avoid conflicts of interest but where this isn't possible you have a duty to identify and declare these so they can be managed in a fair and transparent manner.

Colleagues can access more information on this via our Conflicts of Interest Policy available on the internal intranet page.