CODE OF BUSINESS CONDUCT

Our Commitment of Trust and Integrity to Our Customers

The Capacity Group of Companies endeavors to meet the insurance needs of its Customers with the necessary insurance coverage, service and security at a fair price. We foster a spirit of trust with our Customers that rests on the twin pillars of honesty and integrity. The cornerstone of this relationship with our Customers is the disclosure and transparency of the compensation arrangements for services we provide to our Customers and insurers.

Our Commitment To Integrity And High Ethical Standards

We will never place our own financial or other interests over those of our Customers. To bolster our commitment to our Customers and to the highest ethical standards of behavior, we require all our employees and licensed producers to observe the fundamentals of our business practices in avoiding even the appearance of any conflicts of interest that relate to the offering and placement of insurance products and services and which include:

Fair Dealing

It is imperative that the needs and interests of our Customers be placed ahead of all other interests. Before giving advise or making recommendations, a diligent effort must be made to learn our Customer’s needs, objectives, and circumstances, and then to offer products and services suitable to such needs.

Treatment of Customers

Customers must be treated fairly and with respect and dignity and we must only make promises to our Customers that we believe we can legitimately fulfill.

Marketing Practices

• Our recommendations and solutions to our Customers will result from our Customer’s best interests.
• We shall always use service fee agreements when we charge fees which disclose the services and value we provide and how we are compensated in clear and understandable terms.
• We shall provide our Customers with the proposals of the best available insurer which will be the most suitable insurer that is willing to provide the requested coverage for our Customers taking into consideration the coverage to be provided, service, financial security, and price.
• We shall always advise our Customers to select the best available insurer.
• We shall not provide our Customers with false insurance premium quotes.
• We shall not solicit noncompetitive premium quotes from insurers.
• If we suggest multiple insurers, we will provide a recommendation based solely on our good faith evaluation of each of our Customer’s needs.
• We shall always advise our Customers to select the best available insurer from among multiple insurers if suggested to our Customers.
• We shall always take reasonable measures to obtain a quote from an insurer that might be a best available insurer.
• We will monitor these commitments by a series of internal controls, including regular compliance reviews and audits.
• We will maintain an 800 number to monitor any Customer complaints relating to our failure to fulfill our commitments to clients.

Disclosure And Transparency

We do represent the interest of the insured in an insurance transaction either by receiving compensation or providing disinterested advice to the prospective insured and we are required to do the following:

• Make a good faith effort to provide a complete and accurate response, with no material omissions or misrepresentations, to questions posed by the insured.
• Assuming we represent multiple insurers in the proposed insurance transaction, either forward to the insured a proposal from each responding insurer, or select the proposals to be forwarded to the insured based solely on objective criteria furnished by the insured or disclosed in writing to the insured.
• A statement that we may receive additional compensation from the insurer based upon other factors, such as premium volume placed with a particular insurer and loss or claims experience, if that is the case.
• A statement of any existing or potential conflicts we may have between the interests of the Client and the interests of any other person, including us, that may impact our recommendation.

If we charge the insured a service fee in an insurance transaction, we are required to provide a written agreement between us and the Client which makes the following disclosures, sufficiently complete and understandable to enable the Client to understand and consider the potential incentives we will receive as producers in the proposed insurance transaction and the costs of the coverage:

• A statement of any compensation to be paid to us or to any related entity that is in addition to the total premium and is not included in the total premium.
• A statement that we, or any related entity, will receive compensation from the insurer or an entity related to the insurer for placing the insurance with the insurer, if that is the case.
• A statement of the duties we will perform on behalf of our Clients.