Code of Ethics & Professional Conduct

BCI Code of Ethics

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C O D E O F E T H I C S A N D P R O F E S S I O N A L C O N D U C T 2 BCI is a leading provider of investment management services to British Columbia's public sector. Our role is to generate investment returns that will help our institutional clients build financially secure futures. With our global outlook, we seek investment opportunities that will meet our clients' risk and return requirements over time. This compels us to integrate long-term environmental, social and governance matters into our investment decisions and activities. We offer investment options across a range of asset classes: fixed income; mortgages; public and private equity; real estate; infrastructure and renewable resources. ABOUT BCI Table of Contents Our Core Values Message from the Chair Message from the Chief Executive Officer / Chief Investment Officer About This Code of Ethics and Professional Conduct Application and Scope Complementary Policies and References Our Responsibilities Employees Leaders and People Managers Chief Compliance & Ethics Officer Human Resources and Governance Committee (HRGC) Audit Committee Our Guiding Principles We Respect Our Duties We Are Honest and Transparent with Our Clients We Do Not Engage in or Facilitate Illegal Activity We Treat Each Other With Dignity and Respect We Promote a Safe and Healthy Work Environment We Avoid Conflicts of Interest We Are Disciplined When Engaging in Outside Activities We Do Not Extend or Accept Inappropriate Business Courtesies We Use Business Resources Appropriately We Protect BCI's Property and Reputation We Preserve the Accuracy and Integrity of Our Records We Engage Business Partners Based on Merit We Are Committed to Responsible Investing We Support Our Community We Value Diversity & Inclusion We Uphold Applicable Rules Governing Capital Markets Our Ethical Decision Making Process Guidance and Support Speaking Up Confidential Reporting Disciplinary Measures for Non-Compliance Training Acknowledgement and Attestations Ethical Decision Tree 3 4 5 6 6 6 7 7 8 8 8 8 9 10 10 11 11 12 12 13 14 15 15 16 17 17 18 18 19 20 20 21 22 23 24 24 25

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