For over 130 years, Prudential has helped customers achieve financial security and peace of mind. Prudential accomplishes this mission by providing our customers with the advice and information they seek through the distribution options of their choice, offering proprietary and non-proprietary insurance and investment products, supported by excellent service. Prudential is a company that our customers trust, and our symbol, the Rock of Gibraltar, signifies our strength and commitment to integrity.

Our Guiding Principles

Prudential recognizes its duty to be socially responsible. We demonstrate our responsibility as a corporate citizen when we interact with our customers, associates, and the community at large, following the guiding principles listed below:

• We build lasting relationships with our customers by offering only those products and services that are appropriate to their needs, provide fair value, and are in compliance with applicable laws and regulations.
• We nurture a culture within the Company that is highly moral, making decisions based on doing the right work in the right way for the right results.
• We ensure no associate's purpose or business group's bottom line is more important than preserving the name and goodwill of Prudential.
• We foster a climate where all associates act with courage, integrity, honesty, and fairness. We are committed to creating an atmosphere that is free of discrimination or harassment of any kind, and where differences are respected and valued.
• We provide an engaging work environment, where associates can learn, grow, and develop, both professionally and personally.

We hold all of our associates to the highest ethical standards. We clearly articulate those standards, reinforce this through enterprise-wide training programs and show a commitment to the communities in which we operate. We provide our employees with resources to use when faced with an ethical dilemma and encourage them to offer suggestions and raise issues as they arise.

"Doing the right thing for the right reasons should be the hallmark of how we conduct business with the public, our customers, and our associates."

-Enterprise Ethics Office

Prudential and IMSA
Life insurance, annuities, and long-term care insurance are often a significant part of your financial plan. Accordingly, you expect the highest level of ethical market conduct standards from an insurance company.

Prudential is proud to be a member of the Insurance Marketplace Standards Association (IMSA), a voluntary membership organization whose purpose is to promote high ethical standards in the life insurance industry. Prudential is a charter member of IMSA, earning certification in 1998 when IMSA first certified its member companies.

To become an IMSA member, Prudential committed itself to a specific set of Market Conduct Standards. Prudential then underwent a rigorous internal, as well as independent, assessment to ensure that it met IMSA's Principles and Code of Ethical Market Conduct. IMSA member companies must renew their membership every three years by successfully completing internal and independent assessments of its policies and procedures. This helps ensure continual compliance with IMSA's Principles and Code of Ethical Market Conduct.

What IMSA Means to You the Consumer

The standards set by IMSA help assure customers that member companies are committed to honesty, fairness, and integrity. As an IMSA member, Prudential has made a commitment to maintain high ethical standards in the sale and service of our products.

IMSA Principles and Code of Ethical Market Conduct

The specific standards Prudential is committed to as a member of IMSA include:

• Conducting business according to high standards of honesty and fairness
• Providing competent and customer-focused sales and service
• Reviewing advertising materials to ensure they are clear in purpose, and honest and fair in content
• Handling customer complaints quickly and fairly
• Engaging in fair competition consistent with state and federal laws
• Maintaining a process of supervision and review that ensures compliance with these Principles of Market Conduct

The strength of Prudential is built on a foundation of integrity and a commitment to the highest ethical standards. For further information on the IMSA Principles and Code, view their website at www.imsaethics.org .