Pacific Life Insurance Company and its subsidiaries and affiliates (“Company” or “Pacific Life”) take pride in our longstanding reputation for integrity, which is key to our success. The strength of Pacific Life’s reputation is established, not only in our own actions, but also in the conduct of those we do business with. For that reason, we strive to work with third parties who share our values and uphold the same high ethical standards.

This Third-Party Code of Business Conduct has been developed to share our expectations regarding the ethical conduct of our third-party service providers (“Third-Party Partners”). We expect our Third-Party Partners to take reasonable steps to ensure that this Third-Party Code of Business Conduct is communicated throughout their organization and made available to their employees and subcontractors who work on Pacific Life business. We expect you, as our Third-Party Partner, to share our commitment to comply with the following standards to the extent they are applicable to our business relationship.

Pacific Life expects our Third-Party Partners to provide the highest total quality and:

• Provide consistent, timely, and relevant feedback. 
• Be proactive in suggesting and providing business solutions. 
• Suggest new processes and improve quality of existing processes and services. 
• Address customer needs and concerns promptly. 
• Invoice accurately and in a timely manner. 
• Promote continuous improvement and innovation.
• Engage in ethical business practices.

Although these standards are more precise than values and principle statements, they are not intended to be all-inclusive rules covering every eventuality. When a specific situation is not addressed here, Pacific Life expects our Third-Party Partners to use the values and principles in this Code to guide their actions and maintain the highest ethical standards.

Pacific Life Values

Pacific Life’s culture is built on our purpose – to provide Confidence for Generations – and brought to life through our values. These principles provide a framework for our responsibility to our Company, customers, business partners, and each other. Our company culture starts and is successful because we are committed to living these values every day.

People: Our people are our greatest assets. We continuously develop ourselves and empower each other, embracing our diverse perspectives, experiences, and strengths to actively contribute to our overall success. Pacific Life fosters a work environment that is challenging, inclusive, collaborative, and results-oriented, providing equal employment opportunities and respectful conditions free from harassment and discrimination. Trust and mutual respect are the foundations of a great working relationship, and it is just as important to treat our customers and business partners with respect, fairness, and dignity as we do our coworkers.

Integrity: We do the right thing for our customers, our people, and our communities, and we hold each other accountable for maintaining their trust in our promises. Doing the right thing is always the right thing. We take responsibility for our actions and place the Pacific Life’s interests ahead of personal benefit or gain. We rely on the honesty and integrity of everyone connected to our business to speak up when something doesn’t seem right. Often, the only way we learn of a concern is because someone had the courage to raise it. Integrity also means safeguarding the sensitive and confidential information entrusted to us; all personal information, confidential business information, and company records are treated as Pacific Life property and assets.

Courage: We innovate and make Pacific Life stronger by seeking diverse perspectives, testing different ways of operating, and engaging in a constructive debate. An innovative mindset, actively seeking opportunities while embedding our ethics and values into everything we do, strengthens our long-term strategies and protects our reputation. Reputation is Pacific Life’s overall character as perceived by others. It is the sum of our actions, our culture, and our citizenship, and every decision made on our behalf helps protect it.

Partnership: Relationships are the center of our business and we work together as one team to meet the needs of our key stakeholders. We take pride in being here for the long term. For nearly 160 years, Pacific Life has focused on doing what’s right for our customers, who trust us to protect their families, businesses, and futures. Our financial strength, resilience, and risk mindset enable our customers to worry less and live more, and our commitment extends to the communities where we live and work.

Enduring Strength: We take pride in being here for the long term. Our financial strength, resilience, and risk mindset enable our customers to worry less and live more, and our commitment extends to the communities where we live and work.

Within these values is adherence to a strict code of ethical workplace behavior and professional business conduct. Pacific Life expects our Third-Party Partners and their associates to act in a similar manner. All individuals, whether Pacific Life associates or third-party personnel, are expected to treat others with respect, fairness, and dignity.

People

Work Environment
It is the policy and practice of Pacific Life to provide and promote equal employment opportunities for all applicants and employees. The Company is firmly committed to maintaining a diverse and inclusive workplace based on our values, which stress the quality of our products and services, the importance of teamwork, and the need for all employees to treat each other with dignity and respect. We expect our Third-Party Partners to support these efforts within their own companies, with our customers, with other third parties, and with all others with whom they may interact during their engagement with Pacific Life.

Health and Safety
The health and safety of our people is of primary importance to Pacific Life. Our Third-Party Partners must provide a safe and healthy work environment for all employees working at their sites by maintaining a focus on health and safety and complying with all applicable laws, rules and regulations.

Harassment, Discrimination & Equal Opportunity
Pacific Life is committed to providing a respectful and productive work environment that is free from harassment and discrimination. In keeping with this commitment, the Company maintains a strict policy prohibiting discrimination and/or harassment based on gender, race, color, religion, national origin, ancestry, age, physical or mental disability, medical condition, marital status, military or veteran status, sexual orientation, gender, gender identity, gender expression, or any other characteristic protected by federal, state or local laws. The Company also prohibits sexual harassment and retaliation.

Third-Party Partners are likewise expected to foster a discrimination-free environment, by seeking to eliminate all forms of workplace harassment and retaliation.

Workplace Violence
Any form of violent conduct or threatening, abusive, intimidating, or hostile behavior is strictly prohibited. Possession of weapons on Company property or at Company-sponsored events is prohibited.

Forced Labor, Child Labor and Human Trafficking
Respect for human rights is a fundamental underpinning of the core values of Pacific Life Insurance Company. Pacific Life strives to respect and promote human rights, as defined by the United Nation’s Universal Declaration of Human Rights, in relationships with employees, suppliers and distributors and other third parties with whom we work. More information can be found in the Pacific Life’s Human Rights Policy.

Third-Party Partners must not participate in, or benefit from, any form of forced labor, including bonded labor, forced prison labor, slavery, involuntary servitude, or human trafficking. Third-party associates involved in Pacific Life engagements must have freedom to move around during their employment. Third-Party Partners must not engage in, or benefit from, the use of child labor in any form. Child labor is defined as employing people below the minimum age for employment in accordance with applicable national laws.

Accountability

Conflicts of Interest
An actual conflict of interest exists when business decisions and actions are motivated by personal benefit, interests, or relationships, rather than by the best interest of Pacific Life. A perceived conflict is when business decisions and actions appear to be motivated by personal benefit, interests, or relationships.

Third-Party Partners must not engage in any act which would bring into question the reputation of Pacific Life. Because it is impossible to describe every potential issue, Pacific Life relies on its Third-Party Partners’ commitment to exercise sound judgment, to seek advice when appropriate or when in question, and to adhere to the highest ethical standards when interacting with or representing Pacific Life. Furthermore, each Third-Party Partner must act with integrity in all dealings, whether directly involved with Pacific Life or not.

Questions or disclosures about apparent or actual conflicts of interest should be brought to the attention of Pacific Life at ItStartsWithMe@PacificLife.com.

Gifts and Gratuities
Third Party Partners may receive gifts and gratuities as gestures of goodwill while establishing and maintaining normal, ethical business relationships. Sometimes, though, gratuities cross the line of ethical business conduct and become conflicts of interest and can be in violation of commercial bribery laws and regulations. This happens when gratuities are, or appear to be, intended to improperly influence business decisions or actions. When gratuities cross the line from common courtesies to conflicts of interest, it undermines Pacific Life’s commitment to conducting business with honesty and integrity. The gratuities our Third-Party Partners accept must be unsolicited, infrequent, and consistent with the concepts of common courtesy and ethical conduct. Third-Party Partners must never give or accept cash or cash equivalents (e.g., gift cards) to or from a Pacific Life employee and must never solicit gratuities for personal benefit.

Gifts and Donations on Pacific Life’s Behalf
Third-Party Partners must not offer, make, promise, or authorize any gift, charitable or political contribution, sponsorship, donation, or other payment of value on behalf of, in the name of, or purportedly for the benefit of Pacific Life, without Pacific Life’s prior written authorization. This prohibition applies regardless of value or intent and is meant to protect Pacific Life from any appearance of improper influence, favoritism, or impropriety. Nothing in this section is intended to limit a Third-Party Partner’s own lawful and independent charitable or civic activities that are not made on Pacific Life’s behalf.

Customer Focus/Innovation

Customer Information
Third-Party Partners, their employees and subcontractors may encounter information about Pacific Life employees,  customers, including information about their accounts, because of their engagement with Pacific Life. Third-Party Partners have a responsibility to protect the confidentiality  and integrity of information about customers, consumers, Pacific Life associates or any other individuals, that may be entrusted to them, by technical and organizational means. They should not seek access to such information unless they have a legitimate business reason to do so. If legitimate access is granted, they must take proper steps to protect against the unauthorized release or use of this information.

Confidential and Proprietary Information
Confidential and proprietary information includes all non-public confidential or proprietary information, including information that, if released without authorization, would be harmful to Pacific Life or its customers. This information may be shared with Nth parties (third-parties, fourth parties, etc.)  who have a need to know and who have previously received appropriate authorization. The use of this information for any reason not specified in the written agreement(s) with Pacific Life is strictly prohibited.  Additionally, Pacific Life provides Third-Party Partners with the Pacific Life Insurance Company Third-Party Minimum Control Requirements outlining the minimum control requirements for Pacific Life data.  

Inside Information and Insider Trading
During an engagement, Third-Party Partners may come into possession of information covered by laws relating to insider trading, such information is referred to as inside information.  Whether that inside information is about Pacific Life or the companies it does business with, such as vendors, customers, and other business partners, Third-Party Partners must never engage in the following activities:

• Trade in the securities of any publicly traded company while aware of inside information about that company.
• Recommend or suggest that anyone buys, sells, or retains the stock or other securities of any company when in possession of inside information about that company.
• Disclose inside information other than for the specific business purpose for which the information is intended to be used.
• Disclose inside information if there is reason to believe that the information may be misused.

When in doubt, Third-Party Partners must assume information is material and non-public and must not act upon it. Third-Party Partners and their personnel must not take part in any trading that may appear improper.

Integrity

Fairness to Competitors, Customers, and Others
Treating others fairly is one of the ways we demonstrate our commitment to doing the right thing. Fairness to competitors, customers, and others means that we treat everyone equally and without bias or partiality while providing our products and services and conducting our business in the open market. We do this not only to exemplify our values but to comply with numerous unfair competition laws.

Third-Party Partners must not engage, or appear to engage, in any activity that restricts normal competition in the open marketplace. Examples include:

• Sharing or agreeing to share information regarding the pricing or design of products or other competitive marketing information with competitors.
• Participating in any arrangement with competitors to fix, rig, or coordinate prices.
• Making any agreements with competitors to boycott or refuse to deal with any third-party.

Third-Party Partners may not take advantage of a business opportunity that is intended for Pacific Life which arises during the engagement. Third-Party Partners may not act as a competitor by providing or attempting to provide similar products or services directly to Pacific Life customers.

Anti-Money Laundering
Third Party Partners must comply with all applicable U.S. and international laws and regulations pertaining to the detection, prevention, and reporting of potential money laundering and terrorist financing activities.

Anti-Bribery
Bribes and other improper payments destroy the fairness that is fundamental to the unfettered operation of the marketplaces in which Pacific Life and its peers conduct business. In addition to harming the markets and communities in which it occurs, bribery is illegal under federal and international law and carries with it substantial criminal sanctions as well as debilitating reputational harm to the companies and individuals involved. Third-Party Partners are prohibited from offering, promising, authorizing, paying, giving, soliciting, or accepting anything of value to or from any government official or private person to improperly gain any regulatory, commercial, or contractual advantage.

Government bribery also includes the concept of “facilitating payments”: that is, small amounts that are paid to a government official to induce the official to expedite fulfillment of a routine duty, such as processing governmental paperwork and licenses. Such payments are illegal under certain international anti-bribery rules and are thus prohibited by this policy.

Right to Audit
Pacific Life expects our Third-Party Partners to maintain complete and accurate books, records, and documentation relating to the products or services they provide to, or on behalf of, Pacific Life. Audit rights are set forth in the applicable master agreement or engagement document.  

Financial Integrity and Accurate Books and Records
Pacific Life is committed to honest and accurate financial reporting, and we expect the same as our Third-Party Partners. Third-Party Partners are expected to keep books, records, and accounts that accurately and fairly reflect, in reasonable detail, all transactions and dealings connected to their relationship with Pacific Life. Invoices must be accurate, complete, submitted in a timely manner, and must reflect only the goods and services actually provided. Third-Party Partners must never create false, misleading, incomplete, or artificial records, maintain undisclosed or unrecorded funds or accounts, or misrepresent the nature of any transaction. Any known or suspected inaccuracy, irregularity, or misstatement should be reported promptly.

Fraud, Waste, and Abuse
Pacific Life has zero tolerance for fraud, waste, and abuse. We expect our Third-Party Partners to conduct their activities honestly and to guard any dishonest, deceptive, wasteful, or abusive conduct in connection with Pacific Life business.  This includes, but is not limited to, misrepresentation, falsification of records, theft, misappropriation or misuse of Pacific Life funds, property, or resources, and the submission of false or inflated claims or invoices. Third-Party Partners are expected to maintain reasonable internal controls to prevent, detect, and address fraud, waste, and abuse, and to promptly report to Pacific Life any known or suspected occurrence involving Pacific Life or its business.

Financial Strength

Representing Pacific Life to the Public
Third-Party Partners and their personnel must never speak to the public or release documents on behalf of Pacific Life. They may freely represent their own views, if such statements do not negatively impact on the good name and reputation of Pacific Life. Third-Party Partners may not use Pacific Life’s name or official logo in press releases or other outside communications without prior approval of Pacific Life. Third-Party Partners may not provide project-specific or engagement-specific details of their support of Pacific Life to the public without prior approval of Pacific Life. Requests for such use of Pacific Life’s name or official logo must be routed through Pacific Life for direction and guidance.

Social Media and Emerging Technologies
Pacific Life expects our Third-Party Partners to assist us in protecting the privacy, confidentiality, and interests of not only Pacific Life but also our current and potential products, associates, partners, customers, and competitors. This expectation applies regardless of whether at work, at home, in the community, or online. As a valued Third-Party Partner, your firm, employees and subcontractors are expected to always use good judgment, including when accessing or providing content on social media. We also expect that, while online, Third-Party Partners and their personnel will not mention Pacific Life work or initiatives or information relating to Pacific Life or its customers.

Third-Party Partners must avoid posting items that would reflect adversely on the integrity or reputation of Pacific Life such as statements, photographs, video or audio that reasonably could be viewed as illegal, offensive, malicious, obscene, threatening or intimidating, potentially discriminating or that could disparage customers, co-workers, or business partners. Third-Party Partners must avoid the appearance of acting on behalf of or representing the Company and respect the use of Pacific Life brands, logos, and trademarks.

Community

Community Engagement
Beyond our business commitments, Pacific Life strives to improve our communities and environment. Through its Foundation, Pacific Life has donated more than $142 million to communities where our employees live and work, creating a positive societal change. Third Party Partners are expected to act as good corporate citizens and are encouraged to participate in community and other local support activities. Third-Party Partners are also encouraged to support community development, including participation in our supplier diversity program.

Environment and Green Initiatives
Pacific Life recognizes that environmental responsibility is essential to providing world-class products and services. Third-Party Partners are expected to comply with the letter and spirit of applicable environmental laws and regulations, and conduct their activities in an environmentally responsible manner. Partners are encouraged to identify and manage environmental impacts to business operations and reduce environmental impact where possible.

Environmental, Social, and Governance

Pacific Life believes that responsible investing is not only good for the environment and society but also key to our long- term financial strength and our mission to help our clients and their families attain peace of mind and financial security. Pacific Life continually evolves our investment processes and incorporates environmental, social, and governance (ESG) factors to better align our decision-making with our duty to invest responsibility.

Investing responsibly is a key pillar of Pacific Life’s Corporate Social Responsibility program. It aligns with Pacific Life’s Core Values of Accountability for our actions, Financial Strength focused on investing with a long-term view, Integrity to do the right thing, and making a positive impact on our community. Third-Party Partners are encouraged to consider ESG criteria in their business decision-making process.

RESPONSIBLE SOURCING

Pacific Life is committed to sourcing goods and services in a responsible and ethical manner, and we expect our Third-Party Partners to share that commitment. Third-Party Partners are expected to comply with all applicable laws relating to responsible sourcing and supply chain integrity, including those addressing forced labor, human trafficking, and the responsible sourcing of raw materials such as conflict minerals. Third-Party Partners are expected to exercise reasonable due diligence over their supply chains and to provide Pacific Life, upon request, with information reasonably necessary to support Pacific Life’s own responsible-sourcing and compliance efforts.

USE OF ARTIFICIAL INTELLIGENCE

 

At Pacific Life, we are committed to the ethical and responsible use of AI technologies. We recognize the transformative potential of AI in enhancing customer experience, productivity, and creativity. However, we also acknowledge the importance of taking steps to help ensure that these technologies are used in a manner that aligns with our values and ethical standards.

Pacific Life expects our Third-Party Partners and their associates to uphold these same standards whenever AI is used to provide products or services to, or on behalf of, Pacific Life, including AI embedded within a partner's own tools, platforms, or subcontracted services. At a minimum, Third-Party Partners are expected to:

• Comply with the law. Use AI in accordance with all applicable laws, regulations, and industry standards, including those governing insurance, privacy, data protection, automated decision making and the responsible use of artificial intelligence.
• Protect our data. Never input Pacific Life confidential information, personal information, or customer data into AI tools without proper authorization, and never permit Pacific Life data to be used to train or improve AI models without our express written consent.
• Be transparent. Disclose when AI is used to deliver services to Pacific Life, and make clear when content, communications, or decisions are AI-generated so that individuals are not misled into believing they are interacting with a human.
• Keep humans accountable. Ensure that AI supports — but does not replace — human judgment, and that a qualified person remains responsible for reviewing and approving AI-assisted decisions, particularly those affecting customers.
• Be fair. Take reasonable steps to prevent bias and avoid discriminatory or unfair outcomes in any AI system used on Pacific Life's behalf.
• Verify accuracy. Review and validate AI-generated outputs for accuracy, reliability, and appropriateness before relying on or delivering them.
• Maintain security. Apply appropriate safeguards to protect AI tools, models, and data from misuse, unauthorized access, or leakage, consistent with Pacific Life's information security requirements.
• Respect ownership. Recognize that data provided by Pacific Life and deliverables produced for Pacific Life remain Pacific Life's property and ensure AI use does not compromise those ownership rights.
• Communicate and cooperate. Notify Pacific Life of any material use of AI or significant model changes relevant to our services, promptly report AI-related incidents, and cooperate with Pacific Life's due diligence and oversight.

Compliance with Laws, Regulations, Policies, and Procedures

As a Third-Party Partner working with Pacific Life, you are required to comply with all applicable laws, rules, regulations and treaties, including but not limited to laws related to anti-money laundering, anti-bribery, competition, business conduct, privacy and data protection, labor and employment, and any other laws described herein or that are otherwise applicable to the products and services you provide to Pacific Life in all locations in which you conduct business operations. 

Sanctions and Export Controls

Pacific Life expects our Third-Party Partners to comply with all applicable economic sanctions, trade restrictions, anti-boycott, and export controls and regulations, including those administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce, and the U.S. Department of State, as well as any comparable laws of other jurisdictions in which they operate. Third-Party Partners must not engage in any transaction, directly or indirectly, involving a sanctioned country, region, or party, or otherwise cause Pacific Life to violate applicable sanctions or export control laws in connection with the products or services they provide. Third-Party Partners are expected to screen against applicable government restricted-party lists and to notify Pacific Life promptly if they become a restricted party or otherwise subject to sanctions.   

Contact Information and Escalation Procedures

Third-Party Partners are required to contact Pacific Life’s Enterprise Compliance department to report any actual or suspected violations of business conduct. Pacific Life will not retaliate against any party who reports a concern or participates in an investigation. Any sort of retaliation that accompanies a reported violation is against Pacific Life policy and our core value of Integrity.

Any questions regarding the Code of Conduct should also be directed to Pacific Life’s Enterprise Compliance department.

Email: ItStartsWithMe@PacificLife.com

 

Last updated: September 2026