GLB2349 Code of Conduct Training 0819

GLB2349 Code of Conduct

September 2019

VO Welcome to Online Training! Today you're going to learn about Globe Life Inc.'s Code of Business Conduct and Ethics, or "Code of Conduct". You are responsible for reviewing the Code of Conduct and conducting yourself in accordance with it, subject to the law. A copy may be found on the Company's website in the Corporate Governance section at investors.. This online training is intended to increase your awareness of the Code of Conduct and to aid in your understanding of your obligations thereunder.

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GLB2349 Code of Conduct

September 2019

VO Globe Life Inc. and its subsidiaries are committed to maintaining a business atmosphere and working environment based on honesty, fair dealing and sound business ethics. The Code of Conduct expresses the standards of integrity and business conduct that every Company director, officer, employee and contractor must uphold and follow.

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GLB2349 Code of Conduct

September 2019

VO The Code of Conduct does not address every issue that may arise, but sets out basic principles to guide all directors, officers, employees and contractors of the Company in conducting daily business operations and making sound judgments regarding compliance with the law and ethical business conduct. You should seek guidance from your supervisor or the Legal Department if you have any questions about the Code of Conduct or regarding a situation in which you are unsure about how to proceed.

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GLB2349 Code of Conduct

September 2019

VO You are expected to understand, respect and comply in letter and spirit with all laws, rules, and regulations that apply to you in your position with the Company. Although you are not expected to have detailed knowledge of each of these laws, rules and regulations, you should know enough to determine when it is appropriate to seek additional information, training or advice from supervisors, managers or other appropriate personnel.

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GLB2349 Code of Conduct

September 2019

VO Directors, officers, employees and contractors of the Company should avoid any action or interest that conflicts with, or gives the appearance of a conflict with, the Company's interests. Conflicts of interest are prohibited as a matter of Company policy, except under guidelines set forth in a resolution approved by the Globe Life Inc. Board of Directors and separately adopted by the Boards of Directors of its subsidiaries. A copy of this resolution may be obtained from the Legal Department or Office of the Corporate Secretary. If you become aware of a conflict or a potential conflict, you should bring it to the attention of the Legal Department, a supervisor, manager, or other appropriate personnel.

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GLB2349 Code of Conduct

September 2019

VO Conflicts of interest can arise when you take actions or have interests that may make it difficult for you to perform your work for the Company objectively and effectively. Conflicts can also arise if you or a family member receives improper personal benefits from a third party or the Company, as a result of your position with the Company. It is usually a conflict of interest for Company personnel to work simultaneously for a competitor, customer, or service provider. Generally, it is best to avoid any direct or indirect business connection with our competitors, customers or service providers, except when acting on the Company's behalf.

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GLB2349 Code of Conduct

September 2019

VO Conflicts of interest may not always be clear-cut, so if you have a question you should review a copy of the applicable Board resolution or you may consult with management or the Company's Legal Department.

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GLB2349 Code of Conduct

September 2019

VO If you have access to confidential Company information, you are not permitted to use or share that information for stock trading purposes or for any other purpose except the conduct of our business. All non-public Company information should be considered confidential information. Using non-public Company information for one's personal financial benefit or to "tip" others who might make an investment decision on the basis of such information is not only unethical but also illegal.

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