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Respect for human rights is a fundamental attribute underpinning Â鶹´«Ã½â€™s values. We are aligned with and endorse the United Nations’ Universal Declaration of Human Rights, and we strive to respect and promote human rights in our relationships with our employees, suppliers, distributors and other third parties with whom we engage. At Â鶹´«Ã½, we endeavor to create, embrace and sustain a culture of diversity and inclusion that celebrates the individuality and authenticity of our employees, partners, customers and community.

This Policy applies to Â鶹´«Ã½, its subsidiaries, its third-party business partners, and the investments it holds for its own or others’ accounts. Â鶹´«Ã½ maintains an integrated Compliance and Ethics Program that provides avenues for employees, business associates, and other third parties to identify potential issues related to our policies. Investigation and any remediation or recourse is addressed through the terms of governance underlying the applicable Â鶹´«Ã½ Policy. All employees are required to comply with applicable laws and regulations regarding human rights.

Â鶹´«Ã½, as a signatory of the United Nations Principles for Responsible Investment, is committed to investing responsibly, considering material environmental, social and governance factors. These include the evaluation of social- and human rights-related factors. This ensures that human rights are subsumed as a fundamental element of ethical business conduct.

Â鶹´«Ã½ has a Code of Conduct, an Employee Handbook, and corresponding policies that describe employee rights and responsibilities in support of human rights. The Third-Party Code of Business Conduct, Procurement Process, and Third-Party Due Diligence Programs provide guidelines and policies that define expectations for our relationships with third parties.Ìý

Safe and Healthy Workplace

The safety and health of our employees are of paramount importance. Our policy is to provide a safe and healthy workplace and comply with applicable safety and health laws and regulations, as well as internal requirements. We work to provide and maintain a safe, healthy and productive workplace, in consultation with our employees, by addressing and remediating identi­fied risks of accidents, injury and health impacts.

Workplace Security

We are committed to maintaining a workplace that is free from violence, harassment, intimidation, and other unsafe or disruptive conditions due to internal and external threats. Security safeguards for employees are provided, as needed, and are maintained with respect for employee privacy and dignity.

Forced Labor and Human Trafficking

While Â鶹´«Ã½ does not do business in an industry or in jurisdictions where forced labor and human trafficking are high risks, we prohibit the use of all forms of forced labor, including prison labor, indentured labor, bonded labor, military labor, modern forms of slavery and any form of human trafficking.

Child Labor

We prohibit the hiring of individuals that are under 18 years of age for positions in which hazardous work is required.

Work Hours, Wages and Benefits

We compensate employees competitively relative to the industry and local labor market, and in accordance with terms of wage, work hours, overtime, benefits, and other applicable laws.

How to report violations

We strive to create workplaces in which open and honest communication among all employees is valued and respected. Â鶹´«Ã½ is committed to complying with applicable labor and employment laws wherever we operate. ­Anyone who believes a conflict arises between the language of the policy and the laws, customs and practices of the place where he or she works, or who has questions about this policy or would like to report a potential violation of this policy, should raise such concerns to Â鶹´«Ã½ at ItStartsWithMe@PacificLife.com.Ìý

Â鶹´«Ã½ maintains a strong anti-retaliation policy, and no reprisal or retaliatory action will be taken for raising concerns under this Policy. The Company will investigate, address, and respond to the concerns and take appropriate corrective action in response to any violation.Ìý

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Last updated: 10/30/2025