CODE OF BUSINESS CONDUCT

At Nova Mutual Insurance Company, we are committed to fair dealing, honesty and integrity in the conduct of our business. We take our responsibility to our employees, customers and business partners very seriously.

The Nova Mutual Insurance Company Code of Business Conduct is intended to meet the following objectives:

• To demonstrate that Nova Mutual works to conduct itself ethically;
• To describe Nova Mutual’s values and standards of business conduct;
• To define the various forms of conflict of interest and to guide employees and directors on how to
  avoid and/or resolve potentially difficult situations;
• To set out Nova Mutual’s procedures for reporting of conflicts of interest and other issues relating to
  the Code; and
• To promote principles of respect and fairness in the workplace and in dealings with others