The Provident Mutual

The Provident Mutual Code of Conduct

General Policy

The Provident Mutual organization is committed to achieving high standards of business and personal ethics for itself and its personnel. Through performance in accordance with these standards, the Organization and all its employees will merit and enjoy the respect of the public, the business community, policyholders, customers, and regulatory authorities.

It is the personal responsibility of all employees to acquaint themselves with the legal and policy standards and restrictions applicable to their assigned duties and responsibilities, and to conduct themselves accordingly. Over and above the strictly legal aspects involved, all company personnel are expected to observe high standards of business and personal ethics in the discharge of their assigned responsibilities.

Employee Conduct

Each member of the Organization must avoid any action, relationship or situation which could jeopardize of impair the confidence or respect in which the Organization is held by its customers and the general public, or whiteout appears to be contrary to the interests of Provident Mutual or its policyholders.

Employees shall comply fully with all applicable statutes and regulations.

Willful and knowing disregard of the law may result in severe penalties tot the Organization. In its many Business activities, Provident Mutual and its affiliated companies engage in vigorous, fair and ethical competition. Discussions and agreements with competitors concerning pricing or other competitive policies and practices are strictly prohibited.

Conflict of Interest

Provident Mutual annually circulates a policy statement of Conflicts of Interest. The basic policy states that every employee must avoid any interest that conflicts with the interests of Provident Mutual. The document provides detailed examples and explanations of situations and types of transactions which can give rise to conflicts of interest policy of Provident Mutual, all officers and other affected persons are required to submit annually a completed disclosure statement to the Chairman and Chief Executive Officer of Provident Mutual. Each affiliated company has a similar requirement.

Gifts to or by Employees

Employees may not give or receive anything of more than token value to or from any individual or organization with whom Provident Mutual or its affiliates does business, or who is seeking to do business with Provident Mutual or its affiliates. "Token" is defined as having a value of $50 or less.

Certain business courtesies, such as payment for a lunch or dinner in connection with a business meeting, normally would not be a gift within the context of this policy. However, such activity shall be limited in frequency. Employees shall endeavor to avoid any situation where a gift or activity might appear to influence business judgment or relationships. Any question as to whether a gift might appear to be improper of questionable shall be addressed in writing, with a statement of all relevant facts, to the office of the General Counsel.

Political Contributions

No funds or assets of the Company shall be used for federal, state or local political campaign contributions. These prohibitions cover not only direct contributions but also indirect assistance or support of candidates or political parties through purchase of tickets to special dinners or other fund raising events or the furnishing of any other goods, services or equipment to political parties or committees.

No funds or assets of the Company shall be used directly or indirectly for political contributions outside the United States, even where permitted by applicable law, without the prior written approval of the Chief Executive Officer or General Counsel.

The above prohibitions apply only to the direct or indirect use of corporate funds or assets for political purposes and are, of course, not intended to discourage employees from making personal contributions to the candidates, parties or committees of their choice, through the Company’s Political Action Committee. Under no circumstances shall employees be reimbursed in any way for personal contributions.

Confidential Information and Insider Trading

Employees frequently have access to confidential information concerning the Organization’s business and the businesses of present and prospective customers, policyholders and other employees. Safeguarding confidential information is essential to the conduct of our business. Caution and discretion must be exercised in the use of such information, which should be shared only with those who have a clear and legitimate need and right to know.

No employee shall disclose confidential information of any type, to anyone, except persons within the employee’s company who need to know. Information regarding a customer may not be released to third parties, government, or other organizations, without the consent of the customer unless required by law.

Any requests for information arising through a legal process (e.g., subpoena or court order) must first be referred to the office of the General Counsel before the release of information and before the client is contacted.

Selling or acquiring stocks, securities or other investments, on the basis of non public information is prohibited. Securities include stocks, bonds, notes, debentures, or any other interests, instruments, documents or rights which represent securities. Questions concerning the definition of non public information or a security shall be referred to the office or the General Counsel before any transactions are undertaken.

Service and Consumer Concerns

The foundation of the Organization is to provide high quality service to our existing and prospective customers. Each company endeavors to give prompt, courteous and accurate response to inquiries and complaints received from customers. When appropriate adjustments are warranted, employees will make them promptly and courteously. Equally important, we seek to add or improve policies, procedures and products that contribute to customer satisfaction.

Integrity of Records and Compliance with Accounting Procedures

Accuracy and reliability in the preparation of all business records is mandated by law. It is of critical importance to the corporate decision-making process and to the proper discharge of Provident Mutual’s financial, legal and reporting obligations. All business records, expense accounts, vouchers, bills, payroll and service records and other reports are to be prepared with care and honesty. False or misleading entries are not permitted in the books and records of Provident Mutual or Any affiliated company. All corporate funds and assets are to be recorded in accordance with applicable corporate procedures. Compliance with accounting procedures is required at all times. It is the responsibility of all employees to insure that both the letter and the spirit of corporate accounting and internal control procedures are strictly adhered to at all times. They should advise the responsible person in their department of any shortcomings they observe in such procedures.

Administration of the Code

Employees are encouraged to seek guidance regarding application or interpretation of this Code of Conduct and are expected to cooperate fully in any investigation of a potential violation. The statements set forth in this Code of Conduct are intended as guidelines for employees. Routine questions of interpretation regarding the Code shall be directed to the employee’s supervisory officer, and if necessary, referred to the office of the General Counsel. If any employee believes the code may have been violated, the matter shall promptly be reported to the Director of Internal Audit. Violations of the Code of Conduct may be disciplined by the Organization, up to and including dismissal. However, the Code of Conduct does not set forth all of the reasons or situations in which employees may be disciplined.

The Code of Conduct is not an employment contract, and the Organization may at any time modify the provisions of this Code of Conduct as it seems appropriate.