Business Integrity at Prudential

Prudential employees conduct business within a framework of laws, rules, regulations, high ethical standards, policies and procedures. Prudential's enterprise ethics office, known as Global Business Ethics & Integrity, began in 1994 and integrates and guides Prudential's global business ethics programs around the world. It actively supports Prudential's commitment to high standards by facilitating behavior consistent with our code of conduct and by fostering a culture that promotes prevention, detection, and resolution of potential misconduct.

Prudential's Code of Conduct — Making the Right Choices

At Prudential, we are committed to doing business the right way to maintain and enhance our reputation in the marketplace by continuing to earn the trust placed in us by our customers. We hold our employees to high ethical standards, clearly articulated in our code of conduct, Making the Right Choices. This code serves to guide our employees to act in a manner consistent with our company values.

Responsibility and Accountability

It is the responsibility of every Prudential employee to understand and abide by our code of conduct. We hold all our employees accountable for demonstrating a strong moral compass in every aspect of their work in every part of the world.

When Prudential employees are hired, they are required to complete an ethics course and to attest to their commitment to follow the high ethical standards of behavior outlined in our code of conduct. On an ongoing basis, doing business the right way is reinforced through training and education.

In addition, employees are required to disclose any potential or perceived conflicts of interest consistent with our policies and our code of conduct.

Essentials of Our Code of Conduct

Prudential employees operate according to the following essential principles upon which our entire code of conduct is based:

• Act with integrity and make decisions based on high ethical standards.
• Understand and honor the letter and spirit of the laws and regulations that apply to our businesses.
• Foster a fair, respectful, and collaborative work environment.
• Instill and maintain trust in dealings with our customers, shareholders, and partners.
• Understand that managing risk is our business and the responsibility of every Prudential employee.
• Understand that protecting information and assets is critical in meeting our obligation to our customers, our employees, our shareholders and Prudential.

Our Environment

Prudential has a number of resources available for those who seek information about or guidance on the code of conduct, or who wish to report a potential violation of standards or policies. This process encourages employees to seek out local management or their local ethics officers, who are located within Prudential's businesses and functional areas. In addition, Prudential's telephone help line and website are available seven days a week, 24 hours a day, and are continually promoted as resources to report or to seek guidance on ethical issues.

Compliance Enforcement

Prudential has a compliance infrastructure at the corporate and business levels which is responsible for the coordination, oversight, monitoring, and enforcement of Prudential's policies, compliance programs, and activities. Prudential offers compliance training for employees on a variety of topics, and guidance and support are provided from the compliance teams within the businesses. If a Prudential employee fails to comply with applicable laws, rules, regulations, standards, policies and procedures, he or she could be subject to disciplinary action, up to and including termination.

Transparency

Prudential is committed to operating openly, and we believe the best way to address the concerns and questions about how we do business is to continually communicate to our employees our values and to demonstrate integrity in all aspects of conducting business.