Code of Business Conduct & Ethics Compliance with Laws, Rules and Regulations The Company seeks to comply with both the letter and spirit of the laws and regulations in all jurisdictions in which it operates. Corporate Opportunities Employees owe a duty to the Company to advance its legitimate interests when the opportunity arises. Fair Dealing Our goal is to be regarded as a company that does business with integrity. Books and Records We will comply with all financial reporting and accounting regulations in the preparation of our financial statements and underlying records. Insider Trading Employees should never trade securities on the basis of confidential information acquired through their employment relationship. Conflicts of Interest An employee should avoid any situation in which his or her personal interests conflict or would appear to conflict with the Company’s interests. Confidentiality All confidential information concerning the Company obtained by employees, officers, or directors is property of the Company and must be protected. Protection and Proper Use of Company Assets All employees should endeavor to protect the Company’s assets and ensure their proper use. Reporting Violations of Company Policies Any suspected violation of the Code of Conduct should be referred to the supervisor of the relevant department, or to an officer of the Company, at 1.630.522.0392. Please see the Leadership Team section under "About Fidelity Life" heading for a listing of our officers. Anonymous reports may be made through the Listen Up Reports service by calling toll free at 1.866.398.0010, on the web at www.listenupreports.com, or by traditional mail at Listen Up Reports, PO Box 274, Highland Park, IL 60035. The report you make will be sent to the Company by Listen Up Reports, and your identity will be kept strictly confidential.