Hartford Financial Services : Code of Ethics and Business Conduct

CODE OF ETHICS

and

BUSINESS CONDUCT

CODE OF ETHICS AND BUSINESS CONDUCT

TABLE OF CONTENTS
A MESSAGE FROM OUR CHAIRMAN AND CEO, CHRISTOPHER J. SWIFT	3
LIVING THE CODE	4
SPEAK UP	8
CONFLICTS OF INTEREST	11
GIFTS AND ENTERTAINMENT	18
PROTECTING COMPANY INFORMATION	22
ETHICALLY ENGAGE FOR BUSINESS	29
SUSTAINABILITY PRACTICES	. . 36
MANAGER SUPPORT	39
DISCLAIMERS AND RESOURCES	. 42

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2

Doing the right thing every day is core to

The Hartford's character.. Character is central to our company's vision to be exceptional.. We want to be known not only for our financial performance and our value to customers, but also for who we are..

Our annual employee surveys show that nearly all of our employees enthusiastically believe

The Hartford shows a commitment to ethical business decisions and conduct.. We can take great pride in the fact that our results far exceed the top 25 percent of global companies and that we work for a company that values ethical behavior and business practices..

Our stakeholders - customers, partners, investors, employees and regulators - know they can count on us to uphold the highest standards of ethics and compliance.. The strength of our character is validated through recognition from the Ethisphere Institute, which has repeatedly named The Hartford as one of the World's Most Ethical Companies..®

CODE OF ETHICS AND BUSINESS CONDUCT

Let's continue to be recognized as a company that goes well beyond making statements about doing business ethically, and translate those words into action.. A good place to begin is The Hartford's Code of Ethics and Business Conduct, which reinforces our behaviors and provides guidance when the right course of action may not be immediately clear..

Thank you for continuing to protect and sustain

The Hartford's character and reputation for integrity..

Regards,

3

IN THIS SECTION

Harassment and discrimination

Bullying and abusive conduct

Drugs and alcohol abuse

Safety threats

Criminal action disclosures

THE CODE

LIVING

LIVING THE CODE

Our Code of Ethics and Business Conduct is a resource document to guide employees, including officers and managers, on how to make good decisions and conduct business ethically.. The Code addresses specific topics and provides directions for employees on how to handle common situations, where to go for consulting and when to report issues.. Employees must consult the Code and hold themselves accountable to the standards within it.. By doing the right thing, employees foster a culture of compliance and make The Hartford a top workplace..

4

Ask a Question, Raise a Concern

"The Hartford's culture of integrity is foundational to our success and strong reputation. Our ethical principles and mature compliance programs guide employee behavior and influence our strategies, customer interactions, employee experience and community engagement. Every employee, at all levels of the organization, has leadership accountability to maintain the highest standard of our culture."

• Karmela Malone,
  Chief Ethics and Compliance Officer (CECO)

5

LIVING

THE CODE

LIVING

Annual Certification Requirements

As a company, we share a commitment to our values and aim for continual improvement. All employees must agree to certify annually that they have read the Code and fully understand their responsibilities.

New employees will receive training on the Code as part of their onboarding to the Company. After that, employees will receive additional training whenever the Code is significantly revised.

Due to the Code being a series of ongoing obligations that may be

updated throughout the year, employees are expected to periodically review the Code to refresh their understanding of key provisions and stay current on any modifications.

Role Responsibilities

All employees are expected to perform the responsibilities and duties of their role as assigned. Work avoidance behaviors that negatively impact our customers or teammates will be subject to disciplinary action in accordance with the Employee Performance and Behaviors Improvement Policy.

Respecting Others

When we act to include others - sharing knowledge, opinions and decision- making with respect for our differences - everyone benefits. Legally and ethically, we have a responsibility to act in a way that recognizes diverse talents, backgrounds and points of view. When we respect other people and ourselves, we naturally avoid harmful and hurtful behaviors. We have both legal and ethical obligations to be considerate and avoid harming others either emotionally or physically.

Ask a Question, Raise a Concern

HARASSMENT AND DISCRIMINATION

Harassment and discrimination are illegal acts against others based on personal differences such as race, color, gender, religion, age, national origin, disability, veteran status, sexual orientation, gender identity, marital status, ancestry or citizenship status..

The Hartford does not tolerate any form of workplace harassment or discrimination..

We offer equal employment opportunity and make merit-based employment decisions for recruitment, hiring, compensation, training, promotion and termination..

You should:

• Avoid any kind of harassing or intimidating behavior..
• Keep our workplace free of offensive jokes and the display of offensive material..
• Never make unwanted physical contact or sexual advances in the workplace..
• Avoid interfering with someone's work performance..
• Never exhibit hostile behavior or make threats..
• Respect the personal differences of co-workers..

Can a sexually oriented joke be a form of harassment?

6

Ask a Question, Raise a Concern

LIVING

THE CODE

LIVING

How should any legal documents involving employment discrimination or harassment allegations, including a court complaint, charge from a federal, state, municipal or other recognized compliance agency (such as EEOC, DOL) be reported?

BULLYING AND ABUSIVE CONDUCT

Bullying and abusive conduct are terms that refer to the persistent or severe mistreatment of others, not necessarily based on personal differences like harassment and discrimination.. The mistreatment can include verbal, nonverbal, psychological and physical abuse, as well as humiliation..

Mistreatment of others at work can cause significant stress and result in poor work performance, illnesses, absences and low morale.. It's very important to treat others at work with respect, and to report any behavior that seems bullying and abusive..

SAFETY THREATS

The Hartford cares about your safety and the safety of others, and we want you to feel safe and secure while working.. We do not allow threatening behavior, violent conduct or dangerous substances at any workplace location or at an off-site function.. We do not allow weapons in any building containing a Hartford office and, to the extent permitted by law, at any Hartford location or off-site function..

While driving for business or operating a company vehicle for business or personal use, refrain from activities that distract you from driving.. Also, be sure to comply with all federal, state and local laws concerning distracted driving and cellphone usage.. To the extent the law permits you to use a cellphone while driving, you must use a hands-free device with voice-activated dialing features..

LIVING

THE CODE

LIVING

DECISION AID

CRIMINAL ACTION DISCLOSURES

The U..S.. prohibits financial services companies like The Hartford from employing or doing business with people who have been convicted of certain crimes.. In addition, we do not want to employ people with convictions that suggest a potential risk to our employees or our company.. As a result, you must notify us if you, another employee or a business partner are or have been involved with

any of the following criminal actions:

DRUGS AND ALCOHOL ABUSE

Employees are not allowed to use alcohol, illegal drugs or other substances that impair their ability to perform their job at work.. We don't allow the sale, distribution, purchase, possession or use of illegal drugs - or the abuse of legally prescribed drugs - on our premises or while working off-site.. Always use good judgment and moderation when alcohol is

Immediately Speak Up! and report without fear of retaliation, if you are the target

of, or are a bystander ("witness") to any form of harassment, discrimination, bullying, abusive or unsafe conduct against another employee or colleague, regardless of whether the offender is an

•	A conviction for any crime involving
	your conduct in the financial services industry..
•	A conviction for any crime involving
	dishonesty, breach of trust, violence,
	sexual misconduct or illegal possession

•	A conviction for a drug-related crime
	involving conduct that occurred on
	The Hartford property or while engaged
	in The Hartford business..
•	A pretrial diversion or intervention

served at business events..

employee or non-employee or whether that person is on our premises, working off-site or at an off-site business function.

of firearms..

program related to a criminal prosecution

involving dishonesty, breach of trust or

money laundering..

Someone threatened me at work during an argument. Should I just ignore it and let it go?

7

Ask a Question, Raise a Concern

IN THIS SECTION

Ways to share concerns

Frequently asked questions

SPEAK UP

SPEAK UP

Our company takes employee concerns seriously. It's one way we consciously create and protect our culture. Sharing concerns about compliance with our Code, policies or the law is not optional but rather an obligation of everyone at The Hartford. If something doesn't seem right, please report it.

8

Ask a Question, Raise a Concern

WAYS TO SHARE CONCERNS

If you know of or suspect violations of our Code or the law, you can share your concern in many ways, including:

SPEAK UP

HOTLINES

• Call the Fraud Reporting Hotline:
  800-547-9276(WARN)..
• Use the Ombudsperson: 800-289-5012. (The Ombudsperson is available to assist employees by providing guidance but is not a channel that puts the company on notice of a report..)
• File a complaint using EthicsPoint by phone: [phone].

ONLINE

• File a complaint using EthicsPoint via their online reporting service or scan the QR code to report it via a mobile device.. The reporter can choose to remain anonymous..
• Submit toEmployee Relationsvia the requestform..

ADDITIONAL WAYS

• Talk to a manager, they can be a good place to start, if appropriate..
• ContactEmployee Relations..
• Contact yourCompliance Officer..
• ContactKarmela Malone, Chief Ethics and Compliance Officer..

If the matter involves accounting, internal controls or auditing, report it to the General Auditor, who will then review the matter with the Audit Committee of The Hartford's Board of Directors..

Attorneys at The Hartford must report any Code violations in accordance with our SEC Attorney Conduct Rules.. These rules describe how to comply with the reporting requirements of Section 307 of the Sarbanes-Oxley Act.. Any questions should be addressed to Terence Shields..

Can I report my concern anonymously?

9

Ask a Question, Raise a Concern

If you're an employee living in the United Kingdom, you may also

report pursuant to theInternational Whistleblower Policy..

What happens when I report something?

1 0

Ask a Question, Raise a Concern

FREQUENTLY ASKED QUESTIONS

Will I be protected if I report something?

All reports of compliance concerns should only be made in good faith, meaning you honestly believe that your report is truthful.

The Hartford does not tolerate retaliation against anyone who shares their concerns in good faith. If you do suspect any retaliation or disciplinary action for sharing your concerns, be sure to report it immediately. All employees have access to the Retaliation-FreeWorkplace Policy.

How does EthicsPoint work?

Our independent, third-party service provider is always available to receive your compliance concerns, 24 hours a day, seven days a week. You can submit a report at www.EthicsPoint.com or call 866-737-6812 in the U.S. and Canada, or 866-737-6850 in all other countries. Either way, EthicsPoint will send your report

- anonymously if you choose - to The Hartford for follow-up and investigation.

What if I only suspect a violation but don't have all the details to share?

If you have a good faith belief that there has been a potential violation of our Code, policies or the law by anyone affiliated with The Hartford, including business partners, you are obligated to report the matter. Speak up right away to give The Hartford a chance to minimize the risk of legal or financial exposure, as well as possible damage to the reputation we all have worked to build.

SPEAK UP