GOVERNANCE

Corporate Governance Architecture
The Board of Directors of Sagicor Financial Corporation has approved the adoption of a Group-wide, risk-based corporate governance architecture which conforms to international best practice. This architecture is designed to create a formal structure for the establishment, operation and monitoring of Corporate Governance standards and practices throughout the Group and, when fully implemented, will provide the Group with a comprehensive, consistent and integrated governance model. 


Code of Conduct & Business Ethics 
The architecture reflects the ethical and business values that shape and guide Sagicor. Our corporate value system embraces legal, moral and ethical conduct, accountability, corporate social responsibility and leadership. This corporate value system is set out in Sagicor’s Code of Conduct & Business Ethics. The Code is based on the concept of the moral, ethical and legal obligation owed by Sagicor Directors, Management, Employees and Advisors to various stakeholders. It forms the basis of a number of other detailed policies which are intended to provide specific guidance in assisting all of us in applying acceptable standards of legal and ethical practice to our everyday work. 


Fraud and Other Wrongdoing Policy
The Fraud & Other Wrongdoing Policy applies to any fraud, suspected fraud, or other wrongdoing, or suspected wrongdoing involving employees, sales representatives, shareholders, directors, consultants, vendors, contractors and/or any other party with a business relationship with Sagicor. 


Insider Trading Policy
The Insider Trading Policy is designed to promote fair and equitable securities markets for the protection of investors who are not insiders. 


Communicating Alleged Breaches
We invite all Employees, Advisors and other interested parties to become familiar with these policies and to report to Management breaches or suspected breaches of any corporate policy or other possible fraudulent activity. As usual, we encourage open sharing of comments, questions and concerns about any matter with Management directly.


We understand, however, that there will be times when you may not feel comfortable voicing issues directly. To this end, we have established a system to enhance communication within Sagicor, and provide you with a means to communicate anonymously your knowledge of any possible policy violation or unethical behaviour.
This communication system, called SilentWhistle, is hosted by an independent third-party supplier - Allegiance, Inc. The anonymous information communicated through this site goes directly to designated Management for further action as warranted. You can reach this website by going to http://sagicor.silentwhistle.com. Alternatively, you can access the site by selecting the Corporate Governance tab on Sagicor’s corporate website http://www.sagicor.com. There you will be able to access a link to http://sagicor.silentwhistle.com as well as the Code of Conduct & Business Ethics, the Fraud & Other Wrongdoing Policy and the Insider Trading Policy.