Prudential 2021 ESG Report Ethics and Compliance Prudential’s business conduct is guided by Prudential’s Code of Conduct, Making the Right Choices, which is grounded in the Company’s purpose, principles and values. Prudential’s global Compliance Program within our Ethics & Compliance threatening or harassing acts against anyone for reporting in good faith Department (“Compliance Department”) operates independently. It reasonably suspected unethical or unlawful behaviors or practices, and supports risk-smart oversight of business growth and helps protect our anyone participating in an investigation; customers. The Compliance Department promotes a culture of ethical • Providing a toll-free number and web-based reporting mechanism for and compliant conduct, and fosters compliance with policies, programs, employees to report suspected violations of our Code of Conduct or the and applicable legal and regulatory requirements everywhere Prudential law — the Ethics Help Line is operated by an independent third party and does business around the world. is available 24 hours a day, seven days a week in multiple languages, Prudential’s Global Business Ethics and Integrity (“GBEI”) team is the with an option to remain anonymous, where permitted by law; • Ensuring that appropriate grievance mechanisms and procedures enterprise-wide function designed to cultivate our culture of ethical conduct. By reinforcing our customer advocacy role, we endeavor are in place to receive, escalate, and facilitate resolution of concerns to ensure a safe and positive environment for anyone to speak up. promptly and appropriately, including the investigation of reports of Prudential encourages all employees to raise any ethics questions, misconduct and prevention of the recurrence of misconduct; complaints or concerns they may have. We provide all employees a • Appointing Business Ethics Of昀椀cers in the First Line of Defense; and variety of reporting channels, including management, human resources, • Consistent global reporting to address ethical concerns and monitor Business Ethics Of昀椀cers, the Ethics Website, the Ethics telephone Help Line, GBEI, Compliance Of昀椀cers and/or Law Department contacts. emerging trends. Prudential’s global Con昀氀ict of Interest (COI) Program emphasizes GBEI continues to evolve and adapt with the ever-changing industry, transparency, disclosure and mitigation to manage enterprise risk. partnering with Prudential’s businesses to protect their strategic aspirations The COI Program requires all employees to complete a personal COI while enabling compliant and ethical growth. To augment its leadership for disclosure at the time of hire, as well as at various intervals throughout ethical conduct, key areas of the Ethics and Compliance Program include: their employment. The COI Program also requires businesses and • Reinforcing Prudential’s Code of Conduct through ethical messaging, corporate functions to identify institutional con昀氀icts of interest, apply communications, and programming; appropriate mitigants and to assess those con昀氀icts annually. • Requiring employees to participate in annual training to reinforce In 2021, the Compliance function rolled out a new training platform that their understanding of Prudential’s Code of Conduct and policies, takes a game-based approach to learning, offering content in short and including the prohibition of any type of illegal or unethical behavior and personalized modules to reinforce and increase employees’ understanding of employees’ obligation to report suspected violations promptly; their obligations. The global con昀氀icts program was highlighted in the training • Creating an environment where employees feel comfortable and safe to to further educate employees about the risks of personal and institutional raise concerns without fear of retaliation; con昀氀icts of interest, how to identify actual, potential and apparent con昀氀icts, • Consistent with relevant legal protections, strictly prohibiting retaliatory, the mitigation of any con昀氀icts, and disclosure requirements. Home Introduction Governance Sustainable Investing People Community Environment About this Report Appendix 10