Third Party Code of Business Conduct

Pacific Life Insurance Company and its subsidiaries and affiliates (“ Company”) take  pride in our longstanding reputation for integrity, which is key to our success. The strength of Pacific Life’s reputation is established, not only on our own actions, but also on the conduct of those we do business. For that reason, we stive to work with third parties who share our values and uphold the same high ethical standards.

This Third-Party Code of Business Conduct has been developed to share our expectations regarding the ethical conduct of our third-party service providers (“Third-Party Partners”). We expect our Third-Party Partners to take reasonable steps to ensure that this Third-Party Code of Business Conduct is communicated throughout their organization and made available to their employees and with subcontractors who work on Pacific Life business. We expect you, as our Third-Party Partner, to share our commitment to comply with the following standards to the extent they are applicable to our business relationship.

Pacific Life expects our Third-Party Partners to provide the highest total quality and:

  • Provide consistent, timely, and relevant feedback. 
  • Be proactive in suggesting and providing business solutions. 
  • Suggest new processes, and improve quality of existing processes and services. 
  • Address customer needs and concerns promptly. 
  • Invoice accurately and in a timely manner. 
  • Promote continuous improvement and innovation.
  • Ethical business practices.

Although policies are more precise than values and principle statements, the policies are not written or intended to be all-inclusive rules covering every eventuality and circumstance. When a specific fact is not addressed in this document, Pacific Life expects our Third-Party Partners to use the values and principles herein to guide their actions and maintain the highest ethical standards.

Pacific Life Values

Pacific Life’s culture is based on our core values highlighted by seven principles. These principles are values-based and provide a framework for our responsibility to our Company, customers, business partners, and each other.  Our company culture starts and is successful because we are committed to living these principles every day.

People: Pacific Life fosters a work environment that is challenging, inclusive, collaborative, and results oriented. We provide equal employment opportunities for all applicants, employees, and contractors and provide respectful conditions that are free from harassment and discrimination.

Accountability: We hold ourselves accountable by taking responsibility for our actions. Our Company, our customers, and our business partners trust us to demonstrate values of honesty, integrity, and trustworthiness. We do so by placing the Company’s interests ahead of our own personal benefit or gain.

Customer Focus: For over 150 years, Pacific Life has focused on doing what’s right for our customers. When our customers purchase life and retirement products, they’re buying a promise that today, tomorrow, or ten years from now, Pacific Life will still be there. Our customers trust us to protect their families, businesses, and futures.

Pacific Life maintains a wide variety of sensitive and confidential information. Technical definitions vary, but for our purposes, it is easiest to think of all personal information, confidential business information, and company records as Pacific Life property and assets.

Trust and mutual respect are the foundations of a great working relationship. It’s just as important to respect our customers and business partners as we do our coworkers.

Integrity: The Company relies on the honesty and integrity of its employees to come forward if they see something that doesn’t seem right. Sometimes, the only way we will find out about a concern is from our employees. You are our front-line defense and have the ability to protect Pacific Life’s reputation and financial strength by speaking up.

Doing the right thing is always the right thing. When we make decisions that are good for the company, we put our co-workers, customers, and business partners first. Our actions exemplify the values of Living the Pacific Life.

Financial Strength: Reputation is Pacific Life’s overall character as perceived by others. It’s the sum of our actions, culture, and citizenship. Simply put, are we seen by the public as the good guys? You can protect our reputation through the decisions you make every day.

Innovation: The innovative mindset, actively seeking opportunities, is an important and exciting focus for Pacific Life’s employees and our future growth. Incorporating our ethics and values into the innovation process, fosters an environment that strengthens our long-term strategies.

Community: The power of our giving has a meaningful impact on our communities in Orange County, CA, Omaha, NE, and Lynchburg, VA. We focus our community investments in: arts & culture; civic, community & the environment; education; and health and human services.

Within these principles is adherence to a strict code of ethical workplace behavior and professional business conduct by our employees. Pacific Life expects our Third-Party Partners and their associates to act in a similar manner. All individuals (whether Pacific Life associates or third-party personnel) are expected to treat others with respect, fairness, and dignity.


Work Environment
It is the policy and practice of Pacific Life to provide and promote equal employment opportunities for all applicants and employees. The Company is firmly committed to maintaining a diverse and inclusive workplace based on our values, which stress the quality of our products and services, the importance of teamwork, and the need for all employees to treat each other with dignity and respect. We expect our Third-Party Partners to support these efforts within their own companies, in our customers, in other third parties, and in all others with whom they may interact in the course of their engagement with Pacific Life.

Health and Safety
The health and safety of our people is of primary importance to Pacific Life. Our Third-Party Partners must provide a safe and healthy work environment for all employees working at their sites by maintaining a focus on health and safety and complying with all applicable laws, rules and regulations.

Harassment, Discrimination & Equal Opportunity
Pacific Life is committed to providing a respectful and productive work environment that is free from harassment and discrimination. In keeping with this commitment, the Company maintains a strict policy prohibiting discrimination and/or harassment based on gender, race, color, religion, national origin, ancestry, age, physical or mental disability, medical condition, marital status, military or veteran status, sexual orientation, gender, gender identity, gender expression, or any other characteristic protected by federal, state or local laws. The Company also prohibits sexual harassment and retaliation.

Third-Party Partners are likewise expected to foster a discrimination-free environment, by seeking to eliminate all forms of workplace harassment and retaliation.

Workplace Violence
Any form of violent conduct or threatening, abusive, intimidating, or hostile behavior is strictly prohibited. Possession of weapons on Company property or at Company-sponsored events is prohibited.

Forced Labor, Child Labor and Human Trafficking
Respect for human rights is a fundamental underpinning of the core values of Pacific Life Insurance Company. Pacific Life strives to respect and promote human rights, as defined by the United Nation’s Universal Declaration of Human Rights, in relationships with employees, suppliers and distributors and other third-parties with whom we work. More information can be found in the Pacific Life’s Human Rights Policy.

Third-Party Partners must not participate in, or benefit from, any form of forced labor, including bonded labor, forced prison labor, slavery, involuntary servitude, or human trafficking. Third-party associates involved in Pacific Life engagements must have the freedom of movement during the course of their employment. Third-Party Partners must not engage in, or benefit from, the use of child labor in any form. Child labor is defined as employing persons below the minimum age for employment in accordance with applicable national laws.


Conflicts of Interest
An actual conflict of interest exists when business decisions and actions are motivated by personal benefit, interests, or relationships, rather than by the best interest of Pacific Life. An apparent conflict is when business decisions and actions appear to be motivated by personal benefit, interests, or relationships.

Third-Party Partners must not engage in any act which would bring into question the reputation of Pacific Life. Because it is impossible to describe every potential issue, Pacific Life relies on its Third-Party Partners’ commitment to exercise sound judgment, to seek advice when appropriate or when in question, and to adhere to the highest ethical standards when interacting with or representing Pacific Life. Furthermore, each Third-Party Partner must act with integrity in all of its dealings, whether directly involved with Pacific Life or not.

Questions or disclosures about apparent or actual conflicts of interest should be brought to the attention of Pacific Life at

Gifts and Gratuities
Third Party Partners may receive gifts and gratuities as gestures of goodwill in the course of establishing and maintaining normal, ethical business relationships. Sometimes, though, gratuities cross the line of ethical business conduct and become conflicts of interest and can be in violation of commercial bribery laws and regulations. This happens when gratuities are, or appear to be, intended to improperly influence business decisions or actions. When gratuities cross the line from common courtesies to conflicts of interest, it undermines Pacific Life’s commitment to conducting business with honesty and integrity. The gratuities our Third-Party Partners accept must be unsolicited, infrequent, and consistent with the concepts of common courtesy and ethical conduct. Third-Party Partners must never give or accept cash or cash equivalents (e.g.. gift cards) to or from a Pacific Life employee and must never solicit gratuities for personal benefit.

Customer Focus/Innovation

Customer Information
Third-Party Partners, their employees and subcontractors may come in contact with information about Pacific Life employees,  customers, including information about their accounts, as a result of their engagement with Pacific Life. Third-Party Partners have a responsibility to protect the confidentiality  and integrity of information about customers, consumers, Pacific Life associates or any other individuals, that may be entrusted to them, by technical and organizational means. They should not seek to access such information unless they have a legitimate business reason to do so. If legitimate access is granted, they must take proper steps to protect against the unauthorized release or use of this information.

Confidential and Proprietary Information
Confidential and proprietary information includes all non-public confidential or proprietary information, including information that, if released without authorization, would be harmful to Pacific Life or its customers. This information may be shared with Nth parties (third-parties, fourth-parties, etc…)  who have a need to know and who have previously received appropriate authorization. The use of this information for any reason not specified in the written agreement(s) with Pacific Life is strictly prohibited.  Additionally, Pacific Life provides Third-Party Partners with the Pacific Life Insurance Company Third-Party Minimum Control Requirements outlining the minimum control requirements for Pacific Life data.  

Inside Information and Insider Trading
During the course of an engagement, Third-Party Partners may come into possession of information covered by laws relating to insider trading, such information is referred to as inside information.  Whether that inside information is about Pacific Life or the companies it does business with, such as vendors, customers, and other business partners, Third-Party Partners must never engage in the following activities:

  • Trade in the securities of any publicly traded company while aware of inside information about that company.
  • Recommend or suggest that anyone buy, sell, or retain the stock or other securities of any company when we are in possession of inside information about that company.
  • Disclose inside information other than for the specific business purpose for which the information is intended to be used.
  • Disclose inside information if we have reason to believe that the information may be misused.

When in doubt, Third-Party Partners must assume information is material and nonpublic and must not act upon it. Third-Party Partners and their personnel must not take part in any trading that may appear improper.


Fairness to Competitors, Customers, and Others
Treating others fairly is one of the ways we demonstrate our commitment to doing the right thing. Fairness to competitors, customers, and others means that we treat everyone equally and without bias or partiality while providing our products and services and conducting our business in the open market. We do this not only to exemplify our values but to comply with numerous unfair competition laws.

Third-Party Partners must not engage, or appear to engage, in any activity that restricts normal competition in the open marketplace. Examples include:

  • Sharing or agreeing to share information regarding the pricing or design of products or other competitive marketing information with competitors.
  • Participating in any arrangement with competitors to fix, rig, or coordinate prices.
  • Making any agreements with competitors to boycott or refuse to deal with any third-party.

Third-Party Partners may not take advantage of a business opportunity that is intended for Pacific Life which arises in the course of the engagement. Third-Party Partners may not act as a competitor by providing or attempting to provide similar products or services directly to Pacific Life customers.

Anti-Money Laundering

Third Party Partners must comply with all applicable U.S. and international laws and regulations pertaining to the detection, prevention, and reporting of potential money laundering and terrorist financing activities.

Bribes and other improper payments destroy the fairness that is fundamental to the unfettered operation of the marketplaces in which Pacific Life and its peers conduct business. In addition to harming the markets and communities in which it occurs, bribery is illegal under federal and international law and carries with it substantial criminal sanctions as well as debilitating reputational harm to the companies and individuals involved. Third Party Partners are prohibited from offering, promising, authorizing, paying, giving, soliciting, or accepting anything of value to or from any government official or private person in order to improperly gain any regulatory, commercial, or contractual advantage.

Government bribery also includes the concept of “facilitating payments”: that is, small amounts that are paid to a government official to induce the official to expedite fulfillment of a routine duty, such as processing governmental paperwork and licenses. Such payments are illegal under certain international anti-bribery rules and are thus prohibited by this policy.

Financial Strength

Representing Pacific Life to the Public
Third-Party Partners and their personnel must never speak to the public or release documents on behalf of Pacific Life. They may freely represent their own views, as long as such statements do not negatively impact the good name and reputation of Pacific Life. Third-Party Partners may not use Pacific Life’s name or official logo in press releases or other outside communications without prior approval of Pacific Life. Third-Party Partners may not provide project-specific or engagement-specific details of their support of Pacific Life to the public without prior approval of Pacific Life. Requests for such use of Pacific Life’s name or official logo must be routed through Pacific Life for direction and guidance.

Social Media and Emerging Technologies
Pacific Life expects our Third-Party Partners to assist us in protecting the privacy, confidentiality, and interests of not only Pacific Life but also our current and potential products, associates, partners, customers, and competitors. This expectation applies regardless of whether at work, at home, in the community, or online. As a valued Third-Party Partner, your firm, employees and subcontractors are expected to use good judgment at all times, including when accessing or providing content on social media. We also expect that, while online, Third-Party Partners and their personnel will not mention Pacific Life work or initiatives or information relating to Pacific Life or its customers.

Third-Party Partners must avoid posting items that would reflect adversely on the integrity or reputation of Pacific Life such as statements, photographs, video or audio that reasonably could be viewed as illegal, offensive, disruptive, malicious, obscene, threatening or intimidating, potentially discriminating or that could disparage customers, co-workers, or business partners. Third-Party Partners must avoid the appearance of acting on behalf of or representing the Company and respect the use of Pacific Life brands, logos, and trademarks.


Community Engagement
Beyond our business commitments, Pacific Life strives to improve our communities and environment. Through its Foundation, Pacific Life has donated more than $142 million to communities where our employees live and work, creating a positive societal change. Third Party Partners are expected to act as good corporate citizens and are encouraged to participate in community and other local support activities. Third-Party Partners are also encouraged to support community development, including participation in our supplier diversity program.

Environment and Green Initiatives
Pacific Life recognizes that environmental responsibility is essential to providing world-class products and services. Third-Party Partners are expected to comply with the letter and spirit of applicable environmental laws and regulations, and conduct their activities in an environmentally responsible manner. Partners are encouraged to identify and manage environmental impacts to business operations and reduce environmental impact where possible.

Environmental, Social and Governance

Pacific Life believes that responsible investing is not only good for the environment and society, but also key to our long-term financial strength and our mission to help our clients and their families attain peace of mind and financial security.  Pacific Life continually evolves our investment processes and incorporates environmental, social, and governance (ESG) factor to better align our decision-making with our duty to invest responsibility.    

Investing responsibly is a key pillar of Pacific Life’s Corporate Social Responsibility program.  It aligns with Pacific Life’s Core Values of Accountability for our actions, Financial Strength focused on investing with a long-term view, Integrity to do the right thing, and making a positive impact on our Community.  Third-Party Partners are encouraged to consider ESG criteria in their business decision-making process.

Compliance with Laws, Regulations, Policies, and Procedures

As a Third-Party Partner working with Pacific Life, you are required to comply with all applicable laws, rules, regulations and treaties, including but not limited to laws related to anti-money laundering, anti-bribery, competition, business conduct, privacy and data protection, labor and employment, and any other laws described herein or that are otherwise applicable to the products and services you provide to Pacific Life in all locations in which you conduct business operations. 

Contact Information and Escalation Procedures

Third-Party Partners are required to contact Pacific Life’s Enterprise Compliance department to report any actual or suspected violations of business conduct. Pacific Life will not retaliate against any party who reports a concern or participates in an investigation. Any sort of retaliation that accompanies a reported violation is against Pacific Life policy and our core value of Integrity.

Any questions regarding the Code of Conduct should also be directed to Pacific Life’s Enterprise Compliance department.



Last updated: February 2024

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