Code of Ethics

The commitment to honest, ethical and legal behavior is not only fundamental to the philosophy of MMIC Group but also to building an atmosphere of trust and cooperation among employees. Business must be conducted in a manner that complies with legal standards, is consistent with our mission and vision, and is in accordance with the company's core values. Every employee is expected to demonstrate high levels of honesty, integrity and objectivity, and to avoid actual or apparent conflicts of interest between personal and professional relationships.

This expectation is documented in this Code and the policies and procedures in the Compliance manual and the Employee Handbook. Each employee is obligated to observe the Code of Conduct and Ethics when conducting the business of the MMIC Group. Even if it were not required, as employees of the MMIC Group, we share a common purpose to do what is right, and to treat each other with respect and dignity. In doing so, we provide an environment where employees feel safe, respected, and free from overt or implied harassment and discrimination.

While no statement of policy can cover every situation in which a conflict or prohibited activity may arise, it is expected that all employees will adhere to the principles set forth in this Code of Conduct and exercise their best judgment at all times. The following are areas of particular concern:

  • Each employee must make reasonable efforts to be aware of all laws and regulations relevant to his or her job, and to comply with them.
  • Each employee has the obligation to report any activity that the employee suspects, or reasonably should suspect, violates any law, regulation, or rule, in accordance with established procedures. This obligation to report extends to any suspected violations of laws, regulations, or rules by a client. Information on how to report a concern or suspected violation can be found on ENN by clicking on "EAR", or by asking your supervisor.
  • No employee may discriminate or retaliate against another employee who has, in good faith, complied with the obligation to report concerns about violations or possible violations of any rules and regulations, or MMIC Group policies or procedures.
  • No employee may use any confidential information concerning the MMIC Group's business or its clients and policyholders for an improper purpose.
  • Employees must exercise the highest standard of care and transparency in the preparation of full, fair, accurate, timely and understandable disclosure in required reports and filings.
  • Senior management is expected to set the example and has a heightened obligation of accountability for adherence to this Code of Conduct and Ethics.