Field Conduct

Licensing and Contracting

All representatives must be properly licensed in all states where applications are solicited. This includes solicitation by mail or telephone.

It is the representative’s responsibility to ensure that all applicable licensing requirements are satisfied and current. Representatives must also have errors and omissions insurance coverage satisfactory to the Company.

Anti Money Laundering Act Training (AML)

All representatives will be required to complete ongoing AML training and to provide certification of completion. Standard Life Insurance Company of Indiana has an agreement with LIMRA for this training. You may discuss this with your Marketing Director. Applications received from an agent that has not completed this training cannot be processed.

Completion of Documents and Contract Administration

Applications and customer service documents must contain only the original signatures of the applicants, insured, and owners. No representative or his employees or delegates may sign on behalf of any applicant, insured or owner.

All documents must contain full disclosure and accurate information. Company documents shall not be signed if they are not fully completed. They must be complete in their entirety prior to signing by the customer.

Alteration or changes to applications or other service documents require the customer’s original initials.

It is imperative that the identity of the representative soliciting the application be accurately disclosed on the application.

The customer’s address shall not be changed to an address controlled by a Company representative.

Customer information should not be disclosed to unauthorized third parties.

Handling of Customer Funds

Funds collected on behalf of the Company are received in trust and shall be submitted immediately. Commingling of customer and agent funds is strictly prohibited. All premiums after the initial premium are to be submitted directly to the home office.

Representatives are expected to maintain adequate records and procedures to assure proper handling of customer funds.

Representatives are prohibited from rebating and advancing premiums in violation of the laws of any jurisdiction in which they are licensed.

Policy/Contract Delivery

All policies and contracts must be promptly delivered to customers.

Representatives are required to use policy delivery receipts in designated states. Policy delivery receipts, must be signed and dated by the policy owner at the time of delivery, and promptly returned to the Company.

Representation and Disclosure

Representatives shall not make a misstatement to a customer, the company, to anyone with an interest in a policy or contract or to an insurance department or other regulatory authority. A misstatement includes a statement that is false, is so incomplete as to be misleading or is said in a context that makes it misleading.

Representatives shall fully disclose to the insured, prospective insured, policy owner or the Company, all relevant information regarding a Company policy.

Representatives shall not make any representations, promises or warrants regarding policy benefits or values not specifically stated in the policy contract or rider.

Representatives shall not make any statements, warrants or guarantees regarding the future values of any interest-sensitive products.

Representatives shall give their full and complete cooperation in responding to policy owner complaints or inquiries and shall promptly respond, in writing, when requested by the Company.

Advertising

Representatives are responsible for knowing all laws and regulations and standards relating to the marketing of life and health insurance products in states where they are licensed.

The Company must approve all sales literature and advertising for the Company products prior to use.

Policy Illustrations

If illustrations or other sales materials are used, a copy of all such materials must be left with the applicant at the time the sales presentation is made when requested by the applicant or if required by state law or regulation. Note: The replacement regulations of most states require copies of all sales materials be left with the applicant at the time of presentation.

Illustrations should use only factors and assumptions relevant to the particular insurance policy shown. If a policy is issued other than applied for, a new illustration using the same assumptions, as the policy actually issued, in the form of a contract summary, will be provided.

Any time an illustration is used, the complete illustration must be provided to the policy owner, including pages containing footnotes, disclosures, and guarantees. Explanatory notes and disclosures may not be modified or removed.

Representatives shall not use interest rates greater than current experience. It is recommended applicants be shown illustrations run with interest rates lower than current experience together with the standard current interest rates.

Representatives should always be certain the customer understands the nature of the product he or she is purchasing.

Policy Replacement

Replacement regulations vary from state to state. However, representatives should be aware of the general definition of replacement provided by the National Association of Insurance Commissioners.

Representatives shall disclose to the applicant or policy owner all material information about a proposed policy or contract, or a policy or contract that is being replaced.

Representatives shall not replace policies with the Company or other companies where replacement is not in the best interest of the policy owner.

Application questions must be answered in accordance with state replacement regulations.

It is the representative’s responsibility to know, understand and comply with state regulations where he or she does business.

Non-Compliance

Non-compliance with these Field Conduct Guidelines may result in termination and possibly, termination for cause.

Management will review questionable sales conduct. The Company seeks to ensure that customer complaints and related problems or issues involving sales representatives are dealt with promptly, effectively and consistently.

The acts or omissions described above do not constitute an exclusive list of the reasons for terminating contracts for cause.

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