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Group Gifts and Entertainment Policy Summary

QBE acknowledges that the giving and receiving of gifts and entertainment can be an acceptable business practice, provided these are reasonable, modest, proportionate, and given or received in good faith.

The Group Gifts and Entertainment Policy (“Policy”) applies to all QBE employees, contractors (including contingent workers) and directors. QBE suppliers and third parties should be informed of the principles and requirements of the Policy, where appropriate.

The Policy outlines the requirements when it comes to the giving or receiving of any gifts and entertainment to and from third parties. All QBE employees are also required to complete any mandatory training.

Under the Policy, all QBE employees are not permitted to offer, promise, request or accept gifts and entertainment if:

The monetary value, frequency, duration, or nature is likely to cast doubt on QBE or the external party involved or the employee’s integrity, independence, objectivity or judgement;

It constitutes a bribe under QBE’s Group Code of Ethics and Conduct and Group Financial Crime Framework; or

It would breach applicable laws.