Whistleblower Policy

Purpose and Scope

ShelterPoint Life Insurance Company and its affiliated entities (collectively, “ShelterPoint”) is committed to having a robust Whistleblower Policy (the “Policy”) that encourages all persons to disclose any wrongful conduct that may adversely impact ShelterPoint, its policyholders, employees, or the communities in which ShelterPoint does business.

This Policy applies to any person who has an opportunity to observe wrongful conduct involving ShelterPoint, including current or former employees, agents, consultants, vendors or service providers, outside counsel, customers, or investors.

Definitions

Whistleblowing means the reporting of information or concerns, by one or more individuals or entities, that are reasonably believed by such individual(s) or entity(s) to constitute illegality, fraud, unfair or unethical conduct, mismanagement, abuse of power, unsafe or dangerous activity, or other wrongful conduct, including, but not limited to, any conduct that may affect ShelterPoint’s safety, soundness or reputation.

A Whistleblower is any person who reports any wrongful conduct by or involving ShelterPoint.

A Whistleblower is not responsible for investigating the alleged wrongful conduct or for determining fault or corrective measures. Appropriate senior management officials are charged with these responsibilities.

Examples of Wrongful Conduct

Specific examples of wrongful conduct include, but are not limited to, violations of any state or federal law, violations or noncompliance with a state or federal rule or regulation, violation of fiduciary responsibilities by ShelterPoint to its shareholders, investors, policyholders, claimants or employees.

Employees should refuse to participate in an activity that would result in a violation of state or federal statutes, or a violation or noncompliance with a state or federal rule or regulation.

Please refer to ShelterPoint’s Code of Ethics and Conflict of Interest Policy for additional information.

How to Report Concerns of Wrongful Conduct

If a person has knowledge of, or a concern of, wrongful conduct, the person should immediately contact the Vice President of Human Resources (for employees) or the Chief Legal Officer or Chief Executive Officer (for non-employees):

Carmela D’Avanzo
Vice President, Human Resources
cdavanzo@shelterpoint.com
(516) 504-9334

David G. Melman, Esq.
Senior Vice President & Chief Legal Officer
dmelman@shelterpoint.com
(516) 504-9320

Whistleblower Protections

Whistleblower protections are provided in two important areas -- confidentiality and retaliation.

Confidentiality

All reports of alleged wrongdoing, whether or not they were submitted anonymously, will be kept in strict confidence to the extent possible, consistent with ShelterPoint’s need to conduct an adequate investigation.

Insofar as possible, the confidentiality of the Whistleblower will be maintained. However, identity may need to be disclosed to conduct a thorough investigation, in order to comply with the law, and/or to provide accused individuals their legal rights of defense. To the extent permissible under applicable law, any deviations from ShelterPoint’s policy or practice of confidentiality or anonymity will occur only for a specific, objective, and articulable reason, and only with the involvement of senior compliance and legal management.

Retaliation

ShelterPoint will not retaliate against a Whistleblower. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, or poor work assignments and threats of physical harm. Any Whistleblower who believes they are being retaliated against should contact the Vice President of Human Resources immediately. The right of a Whistleblower to protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.

Employees must exercise sound judgment to avoid baseless allegations. Any employee who intentionally files a false report of wrongdoing will be subject to discipline up to and including termination.

Investigation and Corrective Action

All reports of wrongful conduct will be promptly submitted to the Chief Legal Officer who is responsible for investigating and coordinating corrective action.

Upon receipt of a report of an alleged wrongful conduct, the Chief Legal Officer will record the report, or cause the report to be recorded, on a log to be kept with the Chief Legal Officer.

The Chief Legal Officer will make a determination as to whether a reasonable basis exists for commencing an investigation into the conduct alleged. If a determination is made that an investigation is warranted, appropriate measures will be taken to thoroughly investigate the allegations. The Chief Legal Officer will have authority to obtain assistance from management of ShelterPoint, counsel, and/or auditors, including the retention of outside lawyers or accountants, as are deemed necessary or desirable to conduct the investigation.

If, after investigation, the complaint is determined to be valid, the Chief Legal Officer will, working with the other officers and directors, fashion and implement appropriate corrective action.

Employees and others with any questions regarding this policy should contact the Chief Legal Officer.