Who is NAVEX and what is EthicsPoint?

NAVEX is an independent company that provides a dedicated and secure Speak Up reporting facility to Aviva, called EthicsPoint.

EthicsPoint is available to our employees, contractors, suppliers, business partners, joint venture partners and agents, and allows us to report our concerns confidentially and anonymously should we wish. It is a free 24- hour service which operates seven days a week offering the facility to report in our local language.

Can I raise my concerns to someone completely independent of Aviva?

We provide a number of different ways to Speak Up with all concerns taken seriously. You can report a concern through the EthicsPoint reporting tool, and your identity will not be shared by NAVEX should you specifically ask to remain anonymous. Be assured, you will be heard, protected and supported.

If you feel that reporting your concern through EthicsPoint is still not an appropriate way to raise your concern, the financial regulator in your local region may offer the facility to report concerns directly to them.

Refer to Appendix 1 of the Speak Up Charter for the financial regulator in your local region, and/or ask your local Legal and/or Financial Crime team for details of the financial regulator in your local market.

I'm not sure if what I have observed or heard is a breach of the Business Ethics Code, or involves unethical conduct, but it just doesn't look right to me. What should I do?

Any member of the Speak Up team will be happy to discuss your concerns confidentially and provide guidance. You can contact us by Teams, email or by phone.

Alternatively, file a report with as much detail as possible and the Speak Up team will assess your concerns. We'd rather you report a genuine concern that turns out to be unsubstantiated than let possible unethical behaviour go unchecked.

What's the difference between reporting a concern confidentially or anonymously?

All reports are confidential, but not all reports are raised anonymously.

A concern is raised confidentially where the individual reporting the concern gives their name on the understanding that it is shared only on a strictly need-to-know basis. We make every effort to protect your identity, however, you should be aware that there may be times when the Speak Up team is unable to resolve a concern without revealing your identity, for example where your personal evidence is required. Where this is the case, the Speak Up team will make every effort to obtain your agreement prior to any such disclosure, subject to our legal obligations.

An anonymous report is where the individual raising the concern doesn't provide their name or identity. An anonymous concern can make it much more difficult for us to investigate the matter, protect your position, or to provide you with feedback on the outcome. However, we'd rather you raised your concern anonymously than not at all.

Can I obtain external independent advice?

There are external bodies that may be able to provide independent advice related to your concern. This will vary by market and details of the external bodies, to the extent they exist, can generally be found by performing a search across your local search engines.

In the UK some examples include (but are not limited to):

• Local Union representative
• Protect, a whistle-blower charity
• Financial Reporting Council (FRC)
• Professional Bodies such as Chartered Institute of Internal Auditors
• Chartered Institute of Management Accountants (CIMA)
• Chartered Insurance Institute (CII)
• Citizens Advice
• Information Commissioner's Office
• Law Centres Network

We have a relationship with Protect, a UK charity set up to support people considering raising concerns. We can utilise the online form on its website for independent guidance to help understand whether we should raise a concern and speak up. On its website, Protect publishes a list of non-governmental organisations (NGO) around the world that are directly involved in whistleblowing, and details of the NGOs that provide support and guidance.

What happens if I'm not happy with the way my concern has been investigated?

If you're not satisfied with the outcome of the investigation, you can contact the Group General Counsel who will review the investigation, findings and outcome, and where appropriate commission an additional review. If you're still unhappy with the outcome, you can also raise a concern to your local financial regulator.

Refer to Appendix 1 of the Speak Up Charter for the financial regulator in your local region, and/or ask your local Legal and/or Financial Crime team for details of the financial regulator in your local market.

What if concerns I raised prove to be false?

Where the reported concern is not substantiated, the important thing is that you've acted on a genuinely held concern. If you have raised a genuinely held concern and reported it, it doesn't matter if you're mistaken.

These assurances, however, don't extend to someone who knowingly and maliciously raises a concern they know to be untrue. Any employee knowingly and maliciously raising a concern they know to be untrue is likely to face disciplinary action, up to and including dismissal.

I've reported a concern and I feel that I'm being retaliated against, what should I do?

Retaliation can take many forms and might look like, but is not limited to:

• Disciplinary action without valid grounds
• Unrequested reassignment /relocation
• Bullying and harassment, ostracism, closer monitoring, denial of training, blocking access to resources
• Demotion, suspension, failure to promote without a valid business case

We will not tolerate retaliation against anyone who speaks up and raises a concern in good faith. If you believe you've been unfavourably treated because of raising a concern, please contact Speak Up team or the Group General Counsel, who'll independently review your circumstances. We'll keep what you tell us confidential throughout and beyond the investigation process, subject to our legal obligations.