SEB-Inc. Whistleblower Hotline

Smart Employee Benefits Inc. (the “Corporation”) expects the highest professional and ethical conduct from its directors, officers and employees. All directors, officers and employees of the Corporation are expected to adhere to the principles and procedures set forth in this Code of Business Conduct and Ethics (the “Code”), as applicable. All consultants retained from time to time are also expected to adhere to this Code. This Code outlines the general standards of conduct expected in business practices undertaken by or on behalf of the Corporation.

What to Report:

SEB-Inc. has a Whistleblower Policy that is intended to encourage and enable employees to raise serious concerns about violations of the SEB-Inc. Code of Conduct. The Whistleblower policy provides that employees may report complaints and allegations concerning violations of the SEB-Inc. Code of Conduct to the Board of Directors.

What not to Report

Complaints and allegations will remain anonymous if you choose so but discretion is advised when reporting. This reporting system does not replace the other methods that customers and other stakeholders have traditionally used to communicate with SEB. Customers are encouraged to continue using our existing communication channels.

How to Report

ConfidenceLine™ has been selected by Smart Employee Benefits (SEB) as its authorized external service provider for the purpose of reporting unethical or improper conduct. This service is open to all employees of SEB.

The ConfidenceLine™ e-Web reporting system offers a secure, state of the art, web reporting communications process that allows for direct and confidential communication between you and SEB.

Please find the ConfidenceLine™ Portal and Hotline number below.