Acting with integrity is fundamental to how we operate. It is not only the right thing to do, but it also protects our company and our clients, improves our business performance and can even differentiate us in the marketplace. With today's complex business environment and ever-evolving legal and regulatory requirements, new situations arise where making the right decision requires careful consideration of many factors. Therefore, it’s vital to have  a well-defined code of business ethics by which to operate. Thanks to a set of guiding principles, which we refer to as fundamental behaviors and our governance model, we empower our people to act with integrity every day.  Our Code is organized into four fundamental behaviors. It applies to all our people—regardless of their title or location. Third parties, such as consultants, agents and suppliers, are also required to comply with our Code when acting on our behalf. The following are a list of some of the ethical principles by which each associate, officer and director of Phoenix operate.

Confidentiality

At Phoenix, we value the trust that our clients place in us. Thus, we endeavor to keep our client's documents and personal information confidential unless we receive their express consent or are legally obliged to disclose such confidential information. Keeping our clients' documents and personal details confidential include but is not limited to:

• locking and securing clients' files;
• not disclosing the information contained in a client’s file unless the client consents; and
• ensuring that information about our clients is not disclosed to people who do not need to know.

Diversity and Inclusion

As a company, we depend on innovation and build products to meet the needs of a diverse customer base – this is why diversity at Phoenix Matters. It makes us smarter, leads to better decisions and helps us understand the needs of our customers. Diversity is not just a social imperative, it makes business sense. Our mission is to foster an inclusive environment that provides equal opportunity to our employees, customers, suppliers and the community at large. By creating a corporate culture that is free of harassment or discriminatory treatment of any form, every employee can have the opportunity to contribute fully to the business success of our company. Thus, Phoenix is committed to hiring and cultivating top talent in order to drive business results and position ourselves for the future.

Fairness

We buy and sell based on our business merits without unethical practices. We understand that our Company’s business interests, opportunities and information belong to Phoenix and should only be used in the Company’s best interests. We avoid conflicts of interest. We always advance the Company’s legitimate business interests when an opportunity to do so arises.

Honesty

We tell the truth. If we make a mistake, we do not try to hide it. We behave so that all of our stakeholders can rely on us to do what we say we will do. Whether in our case management processes, responding to a question from a member of the public, talking to a customer or dealing with a supplier or other stakeholder, we are always truthful. We refrain from any conduct that is questionable on ethical grounds.

Neutrality

We aspire to be an independent organization and will therefore continuously review our systems and processes in an effort to highlight any conflicts of interest and any potential risks of conflicts of interest. In delivering our services we will ensure that we do not have interest in the outcome of any services rendered to any client.