Antitrust / Competition Guidelines 1 of 3 January 2018

Accenture Insurance Innovation Executive Board

ANTITRUST POLICY STATEMENT

Because executive boards and similar roundtables can involve meetings of competitors, Accenture wants to emphasize its ongoing commitment to full compliance with all applicable antitrust and competition laws.

This program has been designed and reviewed to ensure its conformity with antitrust standards.An equivalent responsibility for antitrust compliance is yours. Your employer and Accenture depend on your good judgment to avoid all discussions and activities which may involve even the appearance of improper subject matter or improper activities. Accenture will work conscientiously to avoid discussions which may have unintended implications, and Accenture legal counsel has and will continue to provide guidance with regard to these matters. It is important for you to realize, however, that the competitive significance of a particular conduct or communication probably is most evident to you, who are directly involved in the insurance industry.

If you have any concern that a subject of discussion or an activity may not be appropriate, please speak up immediately and we will cease that discussion or activity until we can be advised by legal counsel.

By participating in this Executive Board, you are agreeing to work with Accenture and the other participants at this meeting to ensure full compliance with all applicable antitrust and competition laws.

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Accenture Insurance Innovation Executive Board Antitrust / Competition Guidelines

Executive boards or similar roundtable discussions in which companies interact to exchange ideas about industry offerings and operational matters are of great benefit, both to theparticipants and to Accenture as hosts. However, such discussions can raise risks under competition laws around the world, particularly if some meeting participants compete, or may compete, with one another. Failure to comply with these laws can result in severe consequences for the participants and the companies which they represent, including fines and even imprisonment.

Accenture complies with all competition laws and expects that the Executive Board participants also do so.

The purposes of this Accenture Insurance Innovation Executive Board (the "Executive Board")are to share insights into the major trends shaping the future of the insurance industry, and for Accenture to receive guidance and feedback from its clients on the services and offerings that it provides to the industry.. Participants should keep this purpose in mind and not undertake any activities through the Executive Board or in connection with any related activities that would undermine competition in any segment of the insurance industry.

GUIDANCE

Participants should avoid even the appearance of impropriety. To that end, participants are reminded that, without express permission from counsel, they should not discuss (seriously or in jest):

PRICE OR PRICE RELATED DATA, including:

Individual company prices, price changes, price differentials, price levels, pricing patterns or policies, pricing plans or terms and conditions of sale affecting price such as mark-ups, discounts, credits, allowances, promotions, or credit terms.

Individual company data on costs (including production, inventory distribution or wage, salary or benefits costs), profit margins, production plans, output, capacity, capacity utilization, inventory, sales, or other data that may affect price.

Individual company bids for particular customers or company procedures for responding to bid invitations.

Industry pricing policies, price levels, price changes, pricing procedures, profit margins, capacity, output, or other data that relates to price.

NON-PUBLIC STRATEGIC PLANNING OR MARKETING INFORMATION, including:

Individual company plans concerning the design, production, distribution, or marketing of a product or products.

Individual company strategic plans such as the focus of research and development efforts or the entry into or withdrawal from a product or geographic market.

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AGREEMENTS AMONG COMPETITORS, regarding:

Prices to be charged to customers or paid to vendors.

Current or future levels of production.

The allocation of territories, customers or products.

Restrictions on developing, manufacturing, marketing or selling particular products.

Dealing or not dealing with a competitor, supplier, or customer.

MEETING BEST PRACTICES

1. Accenture will distribute Antitrust Guidelines to all participants, and the Accenture hostwill have a copy of the Antitrust Guidelines available for reference at each meeting.

2. Accenture will create and distribute an agenda prior to each meeting.

3. Accenture will keep minutes that accurately reflect the discussions that occur at eachmeeting. Antitrust counsel will review the draft agendas and meeting minutes.

4. Accenture will lead the session so that the participants adhere to the agenda. In general,subjects not included on the agenda should not be considered at the meeting.

5. If any participant is concerned that another participant is raising a subject which is (ormay be) inappropriate, point out that these events are held on the basis that alldiscussions are conducted in accordance with all relevant competition laws and that, asthis topic seems sensitive, the discussion should move on to a different subject. Eachparticipant has an obligation to stop any discussion or activity that violates theseGuidelines or the antitrust laws generally.

6. Accenture welcomes participation from, and is happy to consult with, competition law counsel.to attend a meeting, please have them contact Accenture competition law counsel.

The antitrust laws are complex and these Guidelines are notexhaustive nor do they attempt to cover every antitrust issue.this Executive Board.

the participants’If a participants’ counsel has questions or concerns or wishes

Please consult with your company’s antitrust counsel on all antitrust issues relating to

January 2018