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Always Do What’s Right.[ T H E AU TO C L U B G R O U P C O D E O F C O N D U C T ]
A Message from Joe RichardsonPresident & CEOTo my ACG colleagues,Do what’s right. This simple yet profound message appears throughout ACG’s Codeof Conduct and is a fundamental principle of how we operate as a business, employerand community member.The Auto Club Group (ACG) continues to build on our AAA history of embracing changeand creating innovative solutions to meet the needs of our members with unwavering integrity.As stated in our corporate values, we are open, honest, and ethical. We safeguardour assets and protect confidential information. Whether an ACG employee, officer,board member, agent, or partner – you play a critical role in demonstrating the realitybehind these words.Join me in reviewing, understanding and following the expected principles and behaviors outlined in this code. As each of us takes individual ownership of doing what’sright, together as OneACG we construct ACG’s strong ethical foundation. By doingthis, we ensure the long-term success of our organization and the confidence of ourcolleagues, members, customers and local communities.Thank you for all that you do and for being part of the ACG team.Sincerely,Joseph J. Richardson Jr.President & CEOThe Auto Club Group
Our Values ConfirmOur CommitmentsConnected Member VisionWe help AAA Members enjoylife’s journey with peace of mind byproviding innovative solutions,advocacy, and membership benefitswherever and whenever theyneed them.Our Connected Member Vision is at the heart of all we do with our five values describing who we are as an organization:Serve Our MembersWe make members our highest priority and strive to create legendary experienceswith every interaction. We create exceptional member value by continuously looking for new and better waysto enhance our members’ lives. We go above and beyond to earn our members’ loyalty by building meaningful lifelong relationships to become their most trusted advisors. Do What’s RightWe are open, honest, ethical, and empowered to do what’s right for our membersand employees. We advocate and take action on issues that affect our community.We are personally accountable for delivering on our commitments. We safeguard our assets and protect confidential information. Lead in Everything We DoWe strive for excellence in all we do by offering best-in-class products, benefits andservices to our members. We embrace change and innovation, acting swiftly with courage and imagination. We are dedicated to growing profitably and delivering outstanding results. We are better today than yesterday. We collaborate across the Federation to strengthen and protect the AAA brand.Value Employees We deeply respect and appreciate our employees and value their perspectives.We invest in our employees and offer opportunities for personal growth andprofessional development. We reward and recognize high performance and celebrate our successes.We Are One ACGWe create an inclusive and welcoming environment of diverse backgrounds, experiences and viewpoints, realizing our differences make us stronger. We respect each other and feel safe to bring our full, authentic selves to work.We think, work and present ourselves as one team dedicated to helping our membersand each other. We are motivated by our common mission to serve members and are passionateabout the work we do.
Table of ContentsOur Commitment Road MapOur Code as a Road Map. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Who Our Code Covers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Our Responsibilities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Our Commitment to ConsumersMaintaining Appropriate Licensure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Avoiding Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Avoiding Inappropriate Business Courtesies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3Explaining Anti-Corruption Guidelines. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Government Corruption. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Commercial Kickbacks and Bribery . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Adhering to International Trade Controls . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Preventing Money Laundering and Terrorist Financing . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Protecting Company Assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Safeguarding Confidential, Sensitive and Proprietary Information . . . . . . . . . . . . . . . . . . 5Record Retention and Disposal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Protecting Intellectual Property. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Preventing Insider Trading of Vendor Securities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Restricting Access to Personal Accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7Using Technology Properly . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7Data Security. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Mobile Devices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Social Media on behalf of ACG . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Complying with Antitrust Laws . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Providing Quality Customer Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Ensuring Financial Integrity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Preventing, Detecting and Reporting Misconduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Safeguarding Vulnerable Groups . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Our Commitment to CommunityInteracting with the News Media . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11Being Socially Responsible . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11Community Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11Civic and Charitable Organization Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Charitable Contributions/Fundraising . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Political Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Environmental Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Our Commitment to Fellow EmployeesEmbracing Diversity, Equity & Inclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13Exercising Anti-Discrimination and Equal Opportunity. . . . . . . . . . . . . . . . . . . . . . . . . . . 13Preventing & Addressing Harassment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13Ensuring Workplace Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Health and Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Workplace Violence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Weapons in the Workplace. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Drug- and Alcohol-Free Workplace . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14(continued)
Table of ContentsOur Commitment to Ensuring Corporate IntegrityReporting Violations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15Supporting Non-Retaliation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15Responding to Audits, Exams and Investigations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15Our Commitment to the MarketplaceEnsuring Third-Party Due Diligence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16Understanding Contractual Relationships . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16Our Commitment to Personal AccountabilityMaintaining Professionalism . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17ACG Code of Conduct & Corporate Policies Acknowledgment. . . . . . . . . . . . . . . . . . . . . . . 17
ECT GEXP ETHINSOMREMOOur Commitment Road MapTMWhat You Should Know . . .Our Code as a Road MapACG maintains a number of avenuesthrough which both management andemployees can ask questions or makereports of actual or suspected misconduct.In addition to discussing with leadership,members of Internal Audit or RegulatoryCompliance, there are specific reportingavenues available as listed below:Our code helps us navigate difficult decisions, but it does not constitute an employmentcontract. Together with corporate policies and values, our code drives the decision-making process to help us arrive at an equitable conclusion. Local Human Resources Fraud and Ethics Reporting Line:Who Our Code CoversOur code pertains to all personnel employed by The Auto Club Group of companies (ACG),including its subsidiaries, affiliates and joint ventures at any location where they perform work on behalf of ACG.Our ResponsibilitiesIndividuals covered by this code are required to conduct themselves in a professional,honest, lawful and ethical manner at all times. If you have a question regarding anysection of this code, contact your manager, your Human Resources representative orCompliance & Ethics Services.877-835-5222 (TELL AAA)Accepts anonymous reports Email to Special Investigations UnitThose holding leadership roles have a responsibility to promote integrity in the workplace, establish a supportive atmosphere of communication and to report and/orescalate any reports of code violations or ethical issues to upper management, SpecialInvestigations, Human Resources, Internal Audit or Regulatory Compliance.In addition to this Code, ACG maintainsseveral Corporate Policiesthat govern standards expected ofall employees.See the Ethics Resources page on The Hub for additional information.THE AUTO CLUB GROUP CODE OF CONDUCT ACG COMPLIANCE & ETHICS SERVICES REVISED. JUNE 20221
Our Commitmentto ConsumersOperating with trust and transparency.What You Should Know . . .Maintaining Appropriate LicensureWhen it comes to assessing the potentialfor conflicts of interest, we must knowhow to define our relationships andinterests.Some positions within ACG require that an employee maintain a professional license.If you are in such a position, you are responsible for maintaining the license incompliance with federal and/or state licensing regulations.For the purposes of this code:Avoiding Conflicts of InterestThe best interests of ACG should be the focal point of your work. You are to avoid situations in which your private interests, those of your family members, or those of individuals with whom you have or have had a close personal relationship, conflict with the bestinterests of ACG. Such situations are considered conflicts of interest and, while havingone is not always a violation of this code, not disclosing one is. In order to maintain animpartial view, all ACG employees must be free from the influence of personal considerations or relationships when working for or giving business recommendations to ACG. “Family members” include your spouse, child, sibling, parent, grandchild, grandparent, uncle, aunt, nephew, niece orcousin (including step, half and in-law).Dependent relatives and/or any otherpersons living in your household canalso be considered family members. A n “outside business organization”includes any person, partnership, firm,corporation, community-based organization or other entity that supplies/transacts or seeks to supply/transactany goods, services or business withACG resulting in payment and/or reimbursement from ACG.Here are some common examples from which a conflict of interest may arise:“Direct or indirect ownership” includesany ownership interest in an outsidebusiness organization, even if the ownership interest is held by an intermediary acting on behalf of you and/or yourfamily members. Ownership of a nominalamount of stock (less than 1%) in a publicly-owned company is not considereda conflict unless the amount is largeenough to influence your judgment. O btaining personal services from known ACG vendors, especially when employed in aposition that has frequent contact with ACG vendors. O wning, either directly or indirectly, any outside business organization as per the definition provided in the “What You Should Know.” sidebar section of this page, or anybusiness that competes with ACG. S erving as an officer, director, partner, consultant, employee or agent of any outsidebusiness organization as per the definition provided in the “What You Should Know ”sidebar section of this page. THE AUTO CLUB GROUP CODE OF CONDUCT Engaging in any outside employment, having a financial interest or ownership involvement with a nonaffiliated insurance, bank, travel or any other business that competeswith ACG.Accepting anything of value that is intended – or could be construed – to influence abusiness decision. Examples include gifts, favors, compensation, commissions, fees,travel or lodging accommodations, or other goods or services from any outside business organization (refer to the ACG Gift Policy.)Hiring or supervising family members or others with whom you have a close personalrelationship.Having a personal interest, financial interest or potential gain in any transactioninvolving ACG.Conducting ACG business with a firm owned or controlled by an employee of ACG, or afamily member of an ACG employee.ACG COMPLIANCE & ETHICS SERVICES REVISED. JUNE 20222
Our Commitment to ConsumersWhat You Should Know . . . Appropriate business courtesies includenominal gifts (items valued at 100 or lessper employee), sharing a meal or attending a sporting or entertainment eventwith a business partner. (continued)Borrowing money from any outside business organization, except loans or advancesfrom banks or other financial institutions, which are offered at prevailing commercialrates and lending standards.Making unapproved brokering or paid business lead referrals to any outside insuranceagent, broker or firm which provides or procures insurance of any type that is available through or from ACG or any of its subsidiary or affiliated companies.Inappropriate gifts from business partners include, but are not limited to, cashor cash equivalents, such as certifiedchecks and gift cards. As employees, wemust neither give nor accept businesscourtesies that actually or potentiallyconstitute unfair business inducements,bribes or kickbacks. More often than not,these actions violate the laws, regulations and policies to which ACG is bound.Soliciting for business courtesies or for special consideration in the settlement ofclaims, the underwriting process or the premium collection process. Obtaining company salvage property, unless the purchase is conducted through anACG-sponsored program, or otherwise approved in advance. Providing false information when conducting business with ACG. Paying for business referrals outside of approved ACG programs.As an ACG employee, you are required to report potential conflicts at least annually, andmore frequently as warranted, to your manager and Compliance & Ethics Services bycompleting an ACG Conflict of Interest Disclosure.If you are unsure about what constitutesan appropriate gift, please review theACG Gift Policy in advance and contactyour manager or Compliance & EthicsServices for guidance.Keep in mind that you may not engage in activities with any outside business organization that may result in a personal benefit to you or a family member at ACG’s expense.This includes taking advantage of a potential business opportunity that ACG may wishto participate in without first disclosing that opportunity to ACG, and allowing ACG ample time to consider whether to pursue it. Likewise, you may not engage in activities orinterests that may influence your decisions on matters involving ACG and the outsidebusiness organization in question.Avoiding Inappropriate Business CourtesiesACG is committed to competing solely on the merit of the products and services weprovide our customers – not the quality of the courtesies we receive from our businesspartners. As such, we should avoid accepting any courtesy that might call our objective decision-making into question, or give the appearance that we have solicited orreceived certain courtesies in exchange for personal gain.For more information about this policy and the related reporting requirements for accepting a gift, please review the ACG Gift Policy. Refer to the ACG Corporate Ticket Policyfor guidelines regarding the purchase and use of event tickets.THE AUTO CLUB GROUP CODE OF CONDUCT ACG COMPLIANCE & ETHICS SERVICES REVISED. JUNE 20223
Our Commitment to Consumers(continued)What You Should Know . . .Explaining Anti-Corruption GuidelinesA “government official” includes anygovernment representative or employee,including those from government-ownedenterprises.ACG’s commitment to integrity includes being compliant with the laws, rules and regulations applicable to any of our business operations. Such laws may vary from placeto place, and we must know and abide by the requirements in all places where weconduct our business.An “export” occurs when a product, service, technology or piece of informationis provided to a person or company inanother country.Government CorruptionThe U.S. Foreign Corrupt Practices Act (FCPA) prohibits giving anything of value, suchas a payment, gift or bribe, to obtain the influence of government officials, candidatesor political parties, even if doing so is customary in a particular place. ACG prohibits“facilitating payments” or fees paid to government officials to speed up routine processes such as the issuance of permits. You must report and document requests formoney or anything of value initiated by a government official. Additionally, if paymentsor anything of value are provided in response to such a request, even if unintentionally,proper reporting and documentation is required by law. ACG maintains uniform processes for the reporting and tracking of legal lobbying activities.What Should You Do?A longtime member came into the branchto reload 4,950 on each of his twoprepaid cards via cash. When asked if hewas planning to travel, he became visiblyuncomfortable. Recalling that the totalcash transaction amount was very closeto the Currency Transaction Report (CTR)mandate of 10,000, do I need to reportthis activity to Field Controls?Commercial Kickbacks and BriberyACG does not pay bribes, nor will we ever offer or accept a “kickback.” This means thatno individual employed by or engaged to provide services to ACG can return or acceptthe return of a sum already paid (or due to be paid) as a reward for making or fosteringbusiness arrangements. ACG also prohibits offering or soliciting improper payments oranything of value in connection with any purchase or sale of products or services inorder to retain or obtain business.Yes, you must report this activity. Thereason behind this reporting is to allowField Controls to evaluate whether tofile a Suspicious Activity Report (SAR)pursuant to the Bank Secrecy Act (BSA)for the customer intentionally structuringa purchase below the CTR threshold.Adhering to International Trade ControlsWhile ACG does not manufacture consumer goods or export physical items to othercountries, it is still important that we have a basic understanding of export controls forthose instances in which they apply to us. For example, there may be times when workduties require international travel. In these situations, voluntary disclosure of confidential business information in some context could be considered an export, and potentially result in a penalty or fine to ACG. If you have any questions regarding internationaltrade controls, contact Regulatory Compliance or the Office of General Counsel.Preventing Money Laundering and Terrorist FinancingACG’s Anti-Money Laundering (AML) program helps prevent ACG’s products and servicesfrom being used for money laundering purposes, illegal financial transactions or othercriminal activity. You are required to comply with all applicable and relevant anti-moneylaundering laws and should only do business with individuals or companies that areengaged in legitimate and lawful business. If you notice any suspicious activity or redflags pertaining to a third party, report the situation to your manager. For more information, refer to the Bank Secrecy Act/Anti-Money Laundering & Office of Foreign AssetsControl Policy.THE AUTO CLUB GROUP CODE OF CONDUCT ACG COMPLIANCE & ETHICS SERVICES REVISED. JUNE 20224
Our Commitment to ConsumersProtecting Company AssetsWhat You Should Know . . . All information related to our business,Those working on ACG’s behalf are trusted to behave responsibly and use goodjudgment when using ACG assets. These assets include, but are not limited to:business partners, employees,members, customers, clients and/orpolicyholders is consideredconfidential and proprietary. Confidential and nonpublicinformation cannot be disclosed without a valid business purposeand management approval. Company-Owned Vehicles Internet Access Electronic Mail Postage Equipment Property and Facilities Furnishings Supplies Information TimeYou have a responsibility to use ACG assets only for authorized business purposes. You maymake occasional, personal use of ACG equipment if the use does not interfere with yourwork or the work of others. Direct questions about the proper use of ACG resources to yourmanager. If your manager is not immediately available, refer to any of the resources listed onpage 1 of this document.What Should You Do?You are approached by a colleague foraccess to a customer list. At first, youthink nothing of it. Though your job titlesand responsibilities differ, you are bothpart of the same team and have workedtogether for months. While you areretrieving this information, your colleaguecasually mentions their sibling is tryingto establish a new business. You startto worry that they may be using this information for personal gain. What shouldyou do?You may not retain any ACG-owned equipment, documents or copies of any business records(electronic-digital), including but not limited to customer records, which were in yourpossession once your employment with ACG ends. For more information, refer to theACG Employment Policy Guide.Safeguarding Confidential, Sensitive and Proprietary InformationConfidential, sensitive and proprietary information is one of the most important assetsin our possession – and protecting such information is integral to our business success. In the event of a subpoena or other legal process requiring the organization todisclose customer information, specific procedures must be followed. Consult with theOffice of General Counsel prior to disclosing any customer information in these circumstances. For more information, refer to the ACG Safeguarding Confidential & SensitiveDocuments Policy.This situation might seem awkward untilyou remember that you are not allowedto share confidential information withoutprior authorization to do so. This is trueeven if the person asking you for suchinformation is a trusted colleague. Youcan ask your coworker what they plan todo with the information, but regardlessof the answer, you should remind themthat you need authorization to grant suchaccess to these details. Consult with amanager and determine whether or notyour colleague’s use of this information isacceptable before sharing it.THE AUTO CLUB GROUP CODE OF CONDUCT(continued) ACG COMPLIANCE & ETHICS SERVICES REVISED. JUNE 20225
Our Commitment to ConsumersRecord Retention and DisposalWhat You Should Know . . . A business record is any data-con-ACG is the sole owner of its business records. ACG information may only be retainedand destroyed in accordance with the ACG Record Retention and Disposal Policy.taining item (paper and/or electronic)regarding a company’s activities. (continued) Intellectual property (IP) is any originalProtecting Intellectual Propertycreative work manifested in a tangibleform that can be legally protected by apatent, trademark or copyright.The same rules that apply to confidential and proprietary information also apply tointellectual property (IP). It is important to protect ACG’s IP as well as that of thirdparties. You may not use any third party IP without the proper licenses or permissions,and you must take special care to follow all applicable terms closely. However, you mayaccess and use information shared with the public, which can include media releasesand presentations. It is important to note that even though we may have receivedpermission to use proprietary information or intellectual property belonging to anotherfor a particular purpose, we must be sure to respect related trademarks and copyrighted material and only use such IP when given express and specific permission to do so.This includes information that may be available on websites and through software. Information that is not public and couldbe viewed as important by a reasonableinvestor in deciding to buy, sell or tradestock is considered inside informationand cannot be used for personal gain.What Should You Do?I just started working at ACG – I camehere from one of our competitors. I oftenget questions from coworkers who wantto know the long-term business strategies of my former employer. Should Ishare such information with my currentcoworkers? It could benefit ACG, and Ihave no sense of loyalty to my previousemployer.Preventing Insider Trading of Vendor SecuritiesACG employees often have access to data considered material, nonpublic or insideinformation. Since ACG is privately held, there is no investment-related inside information that relates specifically to ACG (though our confidential information must beprotected regardless). However, other companies with which we work and interact arepublicly traded, and it is possible for you to learn material, nonpublic information aboutthem. You must not trade or instruct others to trade a company’s stock based on insideinformation.No. You should not bring confidentialproprietary information from a formeremployer to the company. Revealingconfidential information or trade secretsof a former employer is not only unethical– it may also violate the law. Any benefitthat ACG might derive from this knowledge would not be worth the long-termconsequences. Anyone who asks forthis information should be told that it isnot up for discussion. If you need helphandling these kinds of questions, talkto your manager or contact RegulatoryCompliance.Inside information can come in a variety of forms, and can be positive or negative innature. Examples include but are not limited to:Projections of future earnings or losses. News of a pending/proposed merger or joint venture. New product launch or innovative tool. News of a significant sale of assets. Changes in executive management. Insider trading is illegal and can carry serious consequences for ACG and individualsinvolved. If you have any doubts as to whether or not information you possess is considered inside information, seek guidance from Regulatory Compliance.THE AUTO CLUB GROUP CODE OF CONDUCT ACG COMPLIANCE & ETHICS SERVICES REVISED. JUNE 20226
Our Commitment to Consumers(continued)What You Should Know . . .Restricting Access to Personal AccountsWhen it comes to determining accountaccess that could give the potentialappearance of wrongdoing, we mustknow how to define our relationships andinterests.Generally, aside from company records that you review as part of your regular job duties,you may not access any ACG records other than those containing public information orinformation you have disclosed to ACG. You may use online consumer self-service capabilities to transact on existing personal policies, accounts or loans you have with ACG.Within internal employee facing systems, another authorized employee should handle yourpersonal accounts as well as those of individuals with whom you have a close personalrelationship. Additional system-specific restrictions and exceptions are referenced below:For the purposes of this code, ACGdefines “close personal relationship”as a favorable relationship between anemployee and another individual thatcan influence or has the appearance ofpotentially influencing the employee’sjudgm
THE AUTO CLUB GROUP CODE OF CONDUCT ACG COMPLIANCE & ETHICS SERVICES REVISED. JUNE 2022 1 EXPECT SOMETHING Our Commitment Road Map MORETM Our Code as a Road Map Our code helps us navigate difficult decisions, but it does not constitute an employment contract. Together with corporate policies and values, our code drives the decision-mak-
