Business Integrity at Prudential

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 and to continue to earn the trust placed in us by our customers and other stakeholders. Our Code of Conduct, Making the Right Choices, includes our principles, core values and articulates the high ethical business standards expected of everyone associated with Prudential.

 This code serves to guide us to act in a manner consistent with our company purpose, principles and core values.

Responsibility and Accountability

We hold everyone associated with Prudential responsible for understanding and abiding by our Code of Conduct and accountable for working with high ethical standards.

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.

Our Principles Guide Us

We do the right thing.

Above all, we conduct ourselves in an ethical way, recognizing our role as a leader in the global community; we value the trust our customers, employees, investors, partners and communities place in us.

We take a long-term perspective.

We are committed to making lives better over the long term by providing solutions that stand the test of time; we anticipate the implications of our decisions now and in the future and take smart risks.

We win with talent, culture and execution.

Our diverse talent and inclusive culture give us an advantage in the marketplace and allow us to develop and execute on innovative solutions to address our customers’ challenges as they evolve.
 

Prudential is fully committed to supporting and respecting the protection of internationally proclaimed human rights, and to avoiding the company’s involvement in any abuse of human rights around the globe.

We believe we operate in accordance with the United Nations Universal Declaration of Human Rights and the International Labour Organization’s core conventions and recognize and support the United Nations Guiding Principles on Business and Human Rights. 

Prudential works to ensure its policies and practices foster a work environment that upholds our high standards of integrity, which promote responsible citizenship globally.  These attributes form the basis of our Code of Conduct, Making the Right Choices

Respect for human rights is reflected in our policies against discrimination, harassment, and retaliation.  It is honored in our commitment to diversity, inclusion, and accessibility, which is reflected in our Equal Employment Opportunity Policy PDF opens in a new window; and it is demonstrated in the service in which our employees engage in the communities where we live and work. We expect all customers, employees, agents, and business and supply chain partners will be treated with respect and dignity, and that our interactions with others will be free from abuse, discrimination and corruption. As set out in our in our Anti-Human Trafficking and Anti- Slavery Policy PDF opens in a new window, we do not tolerate forced labor, child labor, prison labor, and human trafficking or slavery in any form.
 

Employees

We require all global employees to read and affirm annually, the Code of Conduct and this Human Rights Statement. We also require all global employees to regularly participate in Code of Conduct training.  All U.S. employees have access to human rights training.

We provide our global employees with a safe working environment, and safe working conditions. We expect business and supply chain partners to provide the same for their employees.  Our business and operations fully comply with all applicable labor, safety, health, anti-discrimination and other workplace laws.

Reporting

As reflected in our Code of Conduct and Reporting Concerns and Non-Retaliation Policy, employees who are aware of or reasonably suspect any unethical or unlawful conduct or practices, violations of laws, regulations, or any internal policies — including the Code of Conduct — are obligated to report this information promptly to Prudential.  We provide multiple, safe, accessible reporting channels, which enable concerns to be reported orally, in writing, and/or in person including the Company’s Global Business Ethics & Integrity Hotline Opens in a new tab. Employees may choose to report anonymously, where permitted by local law. Reports are kept confidential, to the extent practicable. We strictly prohibit retaliatory, threatening, or harassing acts against anyone for reporting a concern, in good faith, of unlawful or suspected misconduct, against anyone involved in an investigation of same, or anyone who refused to do something that violates our Code of Conduct, policies or the law, even if that refusal results in the loss of business to Prudential.

Supply Chain 

We expect our business and supply chain partners to demonstrate their commitment to ethical, humane, socially responsible and legally compliant business practices. This includes protecting and preserving human rights and rejecting practices such as the use of   forced labor, prison labor or child labor, and human trafficking and slavery in any form. We are continuing to expand our practice of endeavoring to provide our supply chain partners with a copy of Prudential’s Human Rights Statement and the Supplier Code of Conduct with their contracts.

With our intention to respect human rights throughout our supply chain, we work with suppliers whose human rights policies and practices are consistent with our own. We have set out clear expectations for our suppliers in their management of human rights and other key areas in our Supplier Code of Conduct Opens in a new window.  Prudential’s global Third-Party Agreements and Governance policy and standards include risk based requirements for assessing and managing risk when engaging with third parties. Our critical and highest risk vendors receive a Vendor Control assessment questionnaire that includes questions addressing modern slavery and human trafficking. Our Human Trafficking and Slavery Policy also reflects our expectations of Prudential’s suppliers.

Our Supplier Code of Conduct offers instruction to report any situation in which a supplier believes Prudential or any employee may be in violation of the Supplier Code of Conduct.   

Business Relationships 

We understand that certain business relationships may present heightened human rights risks; in these cases, we would conduct enhanced due diligence to assess these risks and opportunities for mitigation. We aim to identify and address any actual or potential adverse impacts with which we may be involved whether directly or indirectly through our own activities or our business relationships.

Governance

This Human Rights Statement is reviewed on a regular basis to reflect best practice and human rights developments and to adapt our policies and practices accordingly.

The Statement is reviewed by senior management with oversight from the Board of Directors.

Release Date: December 2023 

Anti-bribery and Corruption

The goal of Prudential’s anti-bribery and corruption (ABC) compliance risk management program is to ensure that ABC risks are properly identified, assessed, measured, monitored, and reported. The ABC compliance risk management program helps business management be reasonably assured that effective controls and processes are in place to ensure that (a) Prudential adheres to applicable ABC laws and regulations; (b) any issues uncovered by the ABC risk oversight program are appropriately addressed; and (c) ownership of ABC risks and mitigation actions are assigned to the appropriate business process owners. ABC risk assessments are performed on a periodic basis.

Internal Audit executes its mission by applying a systematic, independent approach to evaluating governance, risk management and control processes, as well as promoting a strong control environment by evaluating the ethical culture established within businesses and corporate functions, and the tone set by business and function heads. This includes performing periodic, risk-based audits of Prudential’s anti-bribery and corruption (ABC) compliance risk management program across our first and second lines of defense globally to ensure compliance with regulatory requirements and Company standards.

For more information about Prudential’s  Anti-Money Laundering and Anti-Bribery/Anti-Corruption Oversight please see the Company’s ESG Report PDF opens in a new tab

Resources for Reporting Ethical Concerns

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 that is responsible for the coordination, oversight, monitoring, and enforcement of Prudential's policies, compliance programs and activities. Prudential offers compliance training for employees and management on a variety of topics. Additionally, 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 of employment.

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 principles and core values and to demonstrate integrity in all aspects of conducting business.