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We adhere to the highest standards of ethical and business conduct, which we believe is critical to meeting both our fiduciary responsibilities and our commitment to deliver stable returns to our clients.

Our Foundational Values 

Our core “GWLRA IS FIT” values – integrity, service, fun, innovation and teamwork – set the foundation for how we conduct our business. Our five values are not just about doing the right thing, but also reflect the way we uphold the fiduciary responsibility we have to our clients and the many individuals who depend on them for their pensions and income savings. 

Business Principles

Two Codes of Business Conduct anchor our responsible business approach: the Great-West Life Assurance Company Code of Business Conduct and Ethics, and the GWL Realty Advisors' Directors Code of Professional Conduct. Our Codes and supporting policies establish the business principles that apply within our organization. 

We extend our high standards of ethical conduct and compliance to our network of service providers who work on our behalf, and expect them to conduct their business in an ethical, environmentally sound and socially responsible manner. These requirements are included as part of the contractual arrangements we have with third parties. 

Feedback Mechanisms

We provide feedback mechanisms to both internal and external parties to ensure they have an opportunity to voice any questions or concerns related to ethical and other issues. Feedback mechanisms are provided through our website as well as through our compliance office and can be used anonymously.

Our whistleblowing policy ensures reports to the organization’s Ombudsman are held in confidence and investigated in a timely manner by the Business Unit Compliance Contact. Where relevant, critical concerns are communicated to our executive team.

Training and Awareness

Training on the Code and our feedback mechanisms are part of our orientation process for all new employees.  We also provide ongoing training on relevant topics, as necessary, such as privacy, anti-corruption, money laundering, and safety, among others. 

Each year, to confirm understanding and attest compliance, all employees are expected to read and sign the Great-West Life Assurance Company Code of Business Conduct and Ethics Code. Designated employees are also expected to read and sign the GWL Realty Advisors’ Directors Code of Professional Conduct.

The Codes are approved by the executive management team.