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Producer Code of Ethics

The Company expects the Producer to understand and follow the rules of ethics and professional conduct listed. Failure to do so may result in termination of their Contract.

The Producer should always:

  1. Properly identify himself/herself, the Company he/she represents, and his/her role in the sales process;
  2. Use an organized sales process that is based on fact-finding and thorough needs analysis;
  3. Use words, terms and symbols which accurately describe the features and benefits of the products being sold;
  4. Disclose to clients accurately, and in language they can understand, all relevant information about the products and services being recommended;
  5. Be aware that the Company does not encourage the replacement of existing insurance coverage of policyholders with other companies. The Producer should recommend a replacement only when it is clear that the new coverage is in the policyholder’s best interest and, if after a careful, thorough and fully documented analysis, it can be shown to provide both short- and long-term benefits to the client that outweigh the costs. The Producer should accurately complete all forms related to a replacement and submit them on a timely basis to the client, the Company, and state insurance authorities, if so required. The Producer shall provide copies of all state-mandated forms and guides to clients at the appropriate time during the sale process;
  6. Maintain complete client files and a master compliance file which includes all Company compliance-related policies and procedures;
  7. Respond on a timely basis to all customer complaints as well as all customer communications.  The Producer must forward written complaints or grievances to the Company as soon as he/she receives them; and
  8. Educate himself/herself about his/her responsibilities as a professional and become knowledgeable about compliance and market conduct rules and regulations in the insurance industry.

The Producer may not:

  1. Call life insurance or annuities “plans,” “programs,” or in any way disguise the fact that they are life insurance policies or contracts;
  2. Provide services such as legal or tax advice, or products such as securities for which he/she is not duly licensed and trained;
  3. Use a certification or professional designation that has not actually been earned;
  4. Show materials to the public which are identified as “For Agent Use Only” or “For Internal Use Only”;
  5. Sell products which do not meet the client’s financial and personal needs;
  6. Exaggerate, inflate or misrepresent products, services or the Company;
  7. Make any statement, written or oral, which is untrue and derogatory regarding the financial condition of any insurance company;
  8. Minimize, ignore, or avoid discussing aspects of products and services because they are complicated or potentially unfavorable;
  9. Develop “home grown” illustrations or advertising or present tabular numerical data which has not been approved by the Company;
  10. Use the terms “vanishing premium” or “vanish” when discussing the mechanics of using accumulated values to pay future premiums; or
  11. Give direct or indirect monetary or “in kind” rebates.