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Code of Business Conduct and Ethics

Purpose & Scope

This Code of Conduct describes Safety Insurance Company’s corporate philosophy and operating guidelines. This Code of Conduct is not a contract. Safety reserves the right to modify any policy at any time, with or without notice.

This Code of Conduct is applicable to the Board of Directors, officers, and employees of Safety Insurance Group, Inc. and all its subsidiaries.

Additional information for employee-related matters can be found on the Human Resources page of the Safety Virtual Community.

Company Values

The reputation of Safety Insurance Group, Inc. (including all subsidiaries, “Safety”) depends on the conduct of its Board of Directors, officers, and employees. Every employee who is associated with Safety must play a part in maintaining our corporate reputation for the highest ethical standards. In addition, Safety Insurance strives to uphold the following corporate values: Service, Profit, Growth, Our People, Management, Citizenship, and Safety. More information regarding these values can be found at https://www.safetyinsurance.com/about/corporate.html.

Compliance with Relevant Laws and Regulations

Adherence to legal and regulatory matters must govern the business decisions and actions of every Safety director, officer, and employee. All directors, officers, and employees shall make every effort to ensure that we and Safety are in compliance with all legal and regulatory matters applicable to our area of employment. Any legal, regulatory, or governmental inquiry or action should be directed to, and will be handled accordingly by, Safety’s Chief Financial Officer.

Non-Retaliation Statement

Safety believes it is essential to create a work environment where employees are empowered to speak freely regarding matters of concern without fear of retaliation. If an employee wishes to anonymously report violations of any laws, regulations, or Company rules, including this Code of Conduct, they may do so by calling the Whistleblower Hotline at (866) 335-6416.

Conflicts of Interest

Safety expects its Board of Directors, officers, and employees to perform their duties using their best impartial judgment in all matters affecting Safety. To maintain independence of judgment and action, directors, officers, and employees must avoid conflict of interest or an appearance of conflict that might arise because of economic or personal self-interest. Directors, officers, and employees shall not engage in activity that conflicts with the interests of Safety. Directors, officers, and employees who reasonably believe they may have interests that conflict with those of Safety shall immediately advise the Chief Financial Officer, who shall review and determine whether to approve of potential conflicts of interest for employees. Review and approval of potential conflicts of interests of officers and directors shall be made by the Audit Committee of the Board of Directors.

The Audit Committee must review any potential hiring of an individual formerly employed by its auditor. A one-year cooling off period is required before the company can hire certain individuals formerly employed by its auditor in a financial reporting oversight role. The Audit Committee will consider whether the hiring of personnel that are or were formerly employed by the audit firm might affect the audit firm’s independence.

Outside Business or Work Conflicts

Safety understands that some employees may have a second job or other outside business commitment. Our time after working hours is our own, as long as the activities do not conflict with the interests of the Company or our policyholders. The responsibility is on the employee in all circumstances to make full disclosure to the Company and to receive written approval where there is any potential conflict. All employees must keep Safety informed in writing of any outside work or business associated with any of Safety’s product lines.

Maintaining Accurate Financial Records/Internal Accounting Controls

It is Safety’s policy to record and report its factual information honestly and accurately. Failure to do so is a serious offense and will subject an individual to severe discipline by the company, as well as possible criminal and civil penalties. Every individual involved in creating, transmitting, or entering information into Safety’s financial and operational records is responsible for doing so fully, accurately, and with appropriate supporting documentation. No officer, employee, or agent may make an entry that intentionally hides or disguises the true nature of any transaction. For example, no individual may understate or overstate known liabilities and assets; record false transactions or record them early; defer or accelerate the proper period for recording items that should be expensed; or process and submit false or inaccurate invoices. Compliance with established accounting procedures, Safety’s system of internal controls, and generally accepted accounting principles is necessary at all times. In order to achieve such compliance, the company’s records, books, and documents must accurately reflect the transactions and provide a full account of Safety’s assets, liabilities, revenues, and expenses. Knowingly entering inaccurate or fraudulent information into Safety’s accounting system is unacceptable and is illegal. Employees who have knowledge that an entry or process is false and material are expected to consult their manager or the Chief Financial Officer. In addition, it is the responsibility of employees to give their cooperation to the company’s authorized internal and external auditors.

Records Management

No funds or assets of Safety shall be used for any purpose which would be in violation of any applicable law or regulation. No fund or asset of Safety shall be established or maintained that is not reflected on the books and records of Safety. No false, artificial, or misleading entries in the books and records of Safety shall be made. All reports and documents that Safety files with the Securities and Exchange Commission or other public communication from Safety will contain full, fair, accurate, timely, and understandable information. No transaction shall be effected and no payment shall be made by or on behalf of Safety with the intention or understanding that the transaction or payment is other than as described in the documentation evidencing the transaction or supporting the payment.

Workplace Safety and Health

Safety makes every effort to provide employees with a safe, secure work environment. Our offices are secured by locked doors equipped with magnetic card readers. Each employee is issued a security card for access to company space within the building. Lost or misplaced security cards must be reported immediately to Human Resources. Safety’s workspace may be accessed from the elevators, which stop on the 2nd, 3rd, 4th, 5th, and 10th floors, or from the “A” stairwell, which has card readers on floors 2-5 and 10. Employees must use their cards to access the building at all times. A card reader is positioned at the security desk on the main floor, as well as at the main door (Broad Street entrance) and in the elevator.

Visitors to the Company are issued visitors’ passes through Human Resources. Visitors must be accompanied by a Safety employee. If an employee sees an unauthorized person in Safety’s workspace, they must tell a manager.

Security measures are in place to control access to the building and our work areas. Situations may arise, however, in which an employee may feel their safety is threatened by co-workers or other sources inside the Company, as well as external sources, such as threats from domestic partners, claimants, or the general public. If an employee feels threatened in any way, they should notify the Human Resources Department immediately. We will take every reasonable step to ensure employee privacy. A policy of confidentiality will be followed, and information will not be disclosed unless there is a genuine need to know. If an employee is witness to or a subject of violence and feels they or others are in imminent danger, they should immediately call the Boston Police (911).

Threats, violence, and intimidation are unacceptable and strictly prohibited, as is possession of weapons. Any talk, even joking, about violence will not be tolerated.

Reporting Accidents

Employees should immediately report all on the job accidents to their manager and to the Human Resources Department. Eligible medical expenses will be paid by the Company’s workers’ compensation insurance. Medical bills for the treatment of work-related injuries should be submitted to Human Resources.

Anti-Corruption/Anti-Bribery

All directors, officers, and employees are strictly prohibited from offering or accepting, either directly or indirectly, anything of value in order to influence action from or secure an advantage to any government official, agency, or entity.

Antitrust & Fair Competition

Safety is committed to complying with all antitrust and fair competition laws. We believe in conducting business fairly and honestly and expect all directors, officers, and employees to respect competitors.

Discrimination & Harassment Prevention

Safety is committed to maintaining a work environment free from harassment, including sexual harassment, where employees are treated with dignity and respect. Discrimination or harassment, including sexual harassment, is contrary to the Company’s policy of providing a safe, secure, and professional work environment for all employees. We will not tolerate harassment of an employee by anyone, including any supervisor, coworker, vendor, or customer of the Company. All employees are required to complete sexual harassment training annually.

Sexual harassment consists of unwelcome sexual conduct when (1) submission to the conduct relates to an employee’s terms or conditions of employment, or (2) when the conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive work environment. Examples of sexual harassment include explicit sexual propositions, sexually suggestive comments or behavior, sexual oriented teasing, joking, language, gestures or material, or physical contact. Often an effective response to sexual harassment is to promptly and firmly tell the offender that his or her behavior is unwelcome and must stop immediately. However, we recognize that circumstances may make this impossible or uncomfortable; an employee may always report harassment directly to the Company. If you feel that you have experienced or witnessed sexual harassment, please immediately notify your manager or a Company representative listed below. You have the right to file a formal complaint. In addition, you may first discuss the situation with one of the Company representatives to consider whether the matter can be satisfactorily resolved in an informal manner. The Company’s policy is to investigate all such complaints promptly and fairly. To the extent practicable, the Company will keep complaints and the terms of their resolution confidential. If an investigation confirms that harassment has occurred, we will act to eliminate the offending conduct and take appropriate corrective action which may include discipline ranging from verbal or written warnings, suspension, transfer, or immediate termination of employment. The Company forbids retaliation against anyone who has reported harassment or cooperated in the investigation.

To make a formal complaint internally, contact one of the following Company representatives:

Name Extension
Chris Harrison 3121
Kathy Anderson 3119

To file a formal complaint with a government agency, contact:

The Massachusetts Commission Against Discrimination (MCAD)

Boston Office:

One Ashburton Place, Room 601 Boston, MA 02108 (617) 727-3990

Springfield Office:

424 Dwight Street, Room 220 Springfield, MA 01103 (413) 739-2145

The United States Equal Employment Opportunity Commission (EEOC) 10 Congress Street-10th Floor Boston, MA 02114 (617) 565-3200

To further the Company’s efforts in preventing sexual discrimination and harassment, Safety does not allow managers and employees over whom they have any supervisory authority to engage in romantic relationships. Such relationships also raise questions of equity, fairness, and favoritism. If such a relationship occurs, the involved parties must promptly discuss the situation with Human Resources or their Vice President to seek a satisfactory resolution. Relationships between employees who are not at the manager/supervisor level are not addressed by this policy. However, if a relationship between two employees results in disruptions in the workplace or other performance problems, disciplinary action may be taken.

Investigations Process of Code Violations

Directors, Officers, and employees of Safety shall be responsible for the enforcement of the policies set forth in this Code and will be held accountable for any violations of this Code. Any officer or employee of Safety having any information or knowledge regarding any transaction or activity prohibited by this Code shall promptly report the same to the Chief Financial Officer. The Chief Financial Officer shall ensure that such information and its source remain confidential. The Chief Financial Officer shall be responsible for promptly formulating any remedial action with respect to violations of this Code by employees, after providing for a full and fair presentation by any effected employee of the facts related to the possible violation of this Code. Any violations of this Code shall be sanctioned, commensurate with the nature of the violation and consistent with other violations of a similar nature, which sanctions may include termination of employment. The Chief Financial Officer shall forthwith bring any information or knowledge regarding potential violations of this Code by a director or officer of Safety to the attention of the Chairman of the Audit Committee of the Board of Directors of Safety. The Audit Committee will be responsible for evaluating the information and developing appropriate remedial actions regarding such violations. Directors, Officers, and appropriate employees of Safety will be required on an annual basis to certify their compliance with this Code.

Gifts & Entertainment

Modest gifts, favors, and entertainment are often used to strengthen business relationships. However, no gift, favor, or entertainment should be accepted or given if it obligates, or appears to obligate, the recipient, or if it might be perceived as an attempt to influence fair judgment. Directors, officers, and employees should not provide any gift or entertainment to customers, suppliers, or others that they would not be able to accept from a customer, supplier, or other applicable party. Never give or accept cash or its equivalent in connection with a business transaction.

Safety’s directors, officers, employees, family members, agents, or agent’s family members are prohibited to offer, accept, or receive a gift or entertainment from any customer, supplier, or any other party with whom a business relationship exists if it:

  • Is in cash
  • Is not consistent with customary business practices
  • Is extravagant in value
  • Can be construed as a kickback, bribe, or payoff in violation of any law, including a bribe to a government official in violation of the U.S. Foreign Corrupt Practices Act
  • Violates any other laws or regulations
  • Could cause embarrassment to or discredit the company if disclosed

Specific laws apply to interactions with government officials and employees. For example, the U.S. and other countries have strict laws that prevent providing anything, including food or beverages, to a government employee.

When a director, officer, or employee is not certain if any gift or proposed gift is appropriate, the matter must be discussed with their supervisor or the Director of the Legal, Regulatory, and Compliance department.

Violations/Disciplinary Measures

Disciplinary Guidelines: The Company expects all employees to perform in a satisfactory manner. However, there are times when disciplinary action becomes necessary. To ensure that employees understand the Company’s rules and performance requirements, the following procedures will be generally followed, but may vary based on the circumstances:

  • 1st Documented Warning: This warning is used when an employee’s performance, attendance, or behavior falls below acceptable standards. It offers an opportunity for the employee to correct the problem. If the problem persists, a second warning may be issued.
  • 2nd Documented Warning: This warning is given to an employee whose performance, attendance, or behavior has not improved to a satisfactory level as the result of an initial warning. It offers a final opportunity for the employee to correct the problem. If the problem persists, termination will likely result.

Warnings are typically in effect for a set period of business days that the employee actively works. The warning is an effort to correct sub-standard performance. If an employee starts an approved leave during the warning period, the warning period is effectively paused for the length of that leave and will resume upon the employees return to work.

Depending on the severity of the problem, further disciplinary action, including termination, may be taken in Safety’s sole discretion without following these disciplinary guidelines.

Insider Trading

This Insider Trading Policy describes the standards of Safety Insurance Group, Inc. and its subsidiaries (the “Company”) regarding trading in the stock and other securities of the Company while in possession of certain confidential information.

Political Activity/Lobbying

Directors, officers, and employees of Safety shall comply with the terms of Safety’s policy statements on Insider Trading and Disclosure.

No contributions shall be made by or on behalf of Safety to any political candidate, party, or campaign either within or without the United States other than in strict compliance with state and federal political finance laws.

Protection of Intellectual Property & Confidential Information

Safety’s property and the property of Safety’s agents and policyholders is to be used solely for the benefit of Safety, its agents, and its policyholders, respectively. You may not use Safety’s, Safety’s agents’, or Safety’s policyholders’ property for personal benefit, nor may you take Safety’s, Safety’s agents’, or Safety’s policyholders’ property with you when you cease working for Safety.

Recognizing and Reporting Issues

The Company aims to settle personnel related problems in a business-like manner. In general, any such problems should be resolved at the supervisory level. However, if this is not possible, our policy for handling employee problems encourages open discussion and prompt resolution.

  • After attempting to resolve the complaint on an informal basis, the employee should report the problem to his/her manager. If the manager is the subject of the complaint, the employee should lodge the complaint with the director. The complaint and all facts pertaining to it should be in writing.
  • If necessary, the manager or director may request group or individual meetings with all parties in order to obtain additional information.
  • The manager or director will respond to the complaint in writing within 3 working days. The response will include a decision on the complaint and the rationale for the decision.
  • If the employee is not satisfied with the decision, the next level of management will review the matter and make the final decision within 2 working days.

Anonymous Employee Reporting of Sarbanes-Oxley Concerns

The Sarbanes-Oxley Act of 2002 (“SOX”) was created to protect employees and investors by increasing corporate responsibility at publicly traded companies and improving the accuracy and accountability of corporate disclosures. SOX includes a requirement for each company’s audit committee to establish procedures for employee whistleblowers to anonymously and confidentially submit concerns and complaints regarding accounting, internal accounting controls, or auditing matters. With your best interests in mind, Safety has contracted with an independent company, The Compliance Partners (“TCP”), to collect and process a concern or complaint you may have about these matters. Their specialists will enable you to provide information anonymously, confidentially, and accurately, so that each complaint can be quickly and efficiently addressed, and if requested, answered. Please refer to the Answers to Frequently Asked Questions on the SVC, for more detailed information. You can contact TCP to find out more about this program or to make a report by using one of the following contact methods:

Toll Free Phone: (866) 335-6416 - (English & Spanish - US Only)
Email: safetyinsurancegroup@signius.com
Toll Free Fax: (866) 332-2699 (US Only)

Fair Dealing with Customers, Suppliers, and Competitors

This Disclosure Policy (the “Policy”) is applicable to all directors, officers, and employees of Safety Insurance Group, Inc. and its subsidiaries (“Safety”). As a publicly traded company, Safety must comply with the disclosure requirements of Regulation FD (Fair Disclosure) under the U.S. securities laws, as well as the provisions of The Sarbanes-Oxley Act of 2002 and of the rules of The NASDAQ Stock Market governing the timely disclosure of market-sensitive information. The goal of Regulation FD is to ensure that all market participants have equal access to market moving, material news. In addition, Sarbanes-Oxley requires that Safety maintain disclosure controls and procedures to ensure that information required to be disclosed by an issuer in its reports is accumulated and communicated to appropriate persons to allow timely decisions about required disclosure. For these reasons, Safety has established a Disclosure Committee (the “Committee”) to implement practices with regard to the disclosure of material information and has adopted this Policy regarding disclosure practices, the dissemination of material information, and the question of which Safety personnel are authorized to speak to analysts, the media, or investors. These guidelines can be found on the SVC and may be revised in the future as practice evolves.

Communicating with External Parties

Safety demands that its employees act at all times with the highest degree of integrity. Safety insists that we treat all individuals with whom we come in contact - policyholders, claimants, employees, agents, competitors, vendors, and colleagues - in a fair and respectful manner. Safety is committed to the maximum utilization of its employees’ abilities and to the principles of equal employment opportunity.

Protection of Company Assets & Resources

Any information that an employee learns about Safety Insurance, or its employees or agents or insureds, as a result of working for Safety Insurance that is not otherwise publicly available, constitutes company/customer data. Employees may not disclose company/customer data to anyone who is not employed by Safety Insurance or to other persons outside Safety who do not need to know such information to assist in rendering services. The disclosure, distribution, electronic transmission, or copying of company/customer data is prohibited. Any employee who discloses confidential Safety information will be subject to disciplinary action (including possible termination).

Data Privacy

Customer/Third Party

The Information Security Policy Overview outlines the policies and procedures in place to protect the Company’s computer systems and the data contained therein. It is reviewed annually and updated as needed by the MIS department. The Information Security Policy Overview can be viewed on the SVC.

Employee

Managers and staff are required to forward all requests for any employee information, including requests for employment references of past or present employees of Safety Insurance, to the Human Resources Department. Employee records are considered highly confidential. The Human Resources Department will not release information, other than job title and dates of employment, to any outside source without written authorization from the employee. Only members of the Safety Insurance Human Resources staff will answer requests for employee information.

Proper Use and Protection of Electronic Communication

Safety expects all employees to access our information systems and computer networks with the upmost responsibility and care.

Through our training platform, there is an annual Information Security Awareness training session, as well as annual Phishing Training. Employees are also periodically tested regarding awareness to phishing schemes through the issuance of ‘test’ phishing emails.

Social Media

Safety Insurance has implemented the following policies for employees who may participate in an online conversation regarding Safety Insurance, or the insurance industry. If you have questions at any time regarding any of the outlined policies, contact Human Resources.

Guidelines

In brief, our guidelines for engaging on the social Web consists of the following core principles: 1. Honesty about who you are 2. Clarity that your opinions are your own 3. Respect and good manners in all communication 4. Good judgment in sharing only public information - including financial data 5. Awareness that what you say is permanent.

Be honest about who you are

If the conversation relates to our business or our industry, you should identify yourself as working for Safety Insurance in the content of your post/comment/other content. Not only is this the ethical thing to do, but there may be personal liability under Federal Trade Commission regulations if you do not. Best practice is always to be honest about who you are without giving out detailed personal information.

Make it clear that the views expressed are yours

Include the following notice somewhere in every social media profile you maintain: “I work at Safety Insurance, but this is my own opinion and is not the opinion of Safety Insurance.”

You speak for yourself, but your actions reflect those at Safety Insurance.

Unless you have been authorized by Executive Management, you cannot speak on behalf of Safety Insurance. Do not portray yourself as a spokesperson, even an “unofficial” spokesperson, on issues relating to Safety Insurance. Realize that people may likely form an opinion about the Company based on the behavior of its personnel.

Use your common sense

It is good business practice for companies (and individuals) to keep certain topics confidential. Respect confidentiality. Refrain from speculation on the future of the Company and its products. Keep topics focused to matters of public record when speaking about the Company or the insurance industry. Do not disclose non-public Company information or the personal information of others.

Mind your manners

Treat past and present co-workers, other personnel, suppliers, consumers, partners, agents, competitors, Safety Insurance, and yourself with respect. Avoid posting materials or comments that may be seen as offensive, demeaning, inappropriate, threatening, or abusive. Acknowledge differences of opinion. Respectfully withdraw from discussions that go off topic or become profane.

The Internet is a public space

Consider everything you post to the Internet the same as anything you would post to a physical bulletin board or submit to a newspaper. Many eyes may see your words, including those of reporters, consumers, your manager, our agents, and the competition. Assume that all these people will be reading every post, no matter how to obscure or secure the site to which you are posting may seem.

An official response may be needed

If you spot a potential issue and believe an official Company response is needed, bring it to the attention of a member of Human Resources before it reaches a crisis situation. Potential issues can often be resolved more effectively and efficiently if they are identified quickly.

Respect the privacy of offline conversations

Protect your co-workers and our partners by refraining from sharing their personal information or any conversations or statements unless you have their written permission to do so. Massachusetts has specific laws about the protection of personal private information (201 CMR 17.00). Bringing someone else into an online conversation without their permission can be destructive to a relationship, cause misunderstandings, or violate laws, commercial contracts, and/or confidentiality agreements.

Same rules and laws apply:

Due to the nature of the digital medium, extra diligence is required in respecting intellectual property (such as copyright and trademark), financial disclosure laws, false advertising, and the like. Ask if you have any questions about what is appropriate, play it smart, and check with a member of Human Resources before posting.

Human Rights & Fair Labor

Safety is committed to upholding fundamental human rights and complying with all fair labor laws and regulations.

Anti-Money Laundering

Safety is committed to fully complying with all anti-money laundering laws. The Company forbids engaging in transactions that facilitate money laundering or result in unlawful diversion. There are internal controls in place to detect and prevent these types of financial transactions.

Waiver Provision

Requests for waivers of this Code shall be submitted to the Chief Financial Officer for consideration by the Board of Directors, who will be responsible for determining whether to grant a waiver. Safety shall report any waiver request granted by the Board in its next periodic report to the Securities and Exchange Commission.

Environmental Stewardship, Diversity & Inclusion, and Social Responsibility

We believe that Safety Insurance has a responsibility to both its stakeholders and the environment in which it operates, and that the effective management of Environmental, Social and Governance (ESG) issues will help drive the continued success of the business. To that end, Safety Insurance is committed to developing environmentally and socially conscious solutions for our employees, our community, our investors and our independent agency partners and policyholders. The latest Environmental, Social, and Governance report can be viewed through the following link: https://www.safetyinsurance.com/about/esg_reports.html.

Substance Abuse/Drug and Alcohol-Free Workplace

Safety prohibits the use of all tobacco products on the premises including but not limited to cigarettes, cigars, marijuana, chewing tobacco, and e-cigarettes or vaping devices.

The Company is committed to maintaining a drug-free workplace and prohibits: 1. The use, sale, purchase, delivery, or possession of illegal drugs at any time or at any place while employed by the Company; 2. The abuse of prescription drugs; 3. The failure to report any known adverse side effects of medication or prescription drugs which an employee may be taking which may affect safety; and 4. Possession or consumption of alcohol or non-prescription drugs while working, or reporting to work under the influence of drugs or alcohol. An exception is made for reasonable social drinking at Company events. Violations of this policy will result in discipline up to and including immediate termination. We may request an employee take a drug and/or alcohol test where there is reason to believe an employee is using such substances at work. You may be subject to immediate termination if you fail to submit to testing on the date and time requested. You also will be subject to immediate termination if you provide an adulterated, substituted, or otherwise tampered specimen.

Charitable Contributions

Community involvement is an important value at Safety Insurance. Safety has established an Employee Gift Matching program which is designed to support the shared commitment to nonprofit and charitable service organizations. This program is designed to match the efforts of all Safety employees. Safety will match qualifying gifts of both individuals and groups of employees from $250.00 up to $5,000.00 (annual maximum per employee). To participate, complete and submit a Matching Funds Request form with the total amount of the contributions to Human Resources. If the amount raised was from a group, then this should consist of a listing of Safety employees who contributed to the organization/event and the respective amounts for each. Safety Insurance has selected Fidelity Management Trust Company (FMTC) to administer our matching gift program. Human Resources will submit all requests to FMTC, who will verify the 501(c)(3) or other applicable revenue code exemption of the charity and determine if your gift is eligible for corporate matching funds. All matching funding will be made directly to the charitable organization via FMTC on a quarterly basis. Nonprofit organizations that are certified as tax exempt under section 501(c)(3) of the Internal Revenue Code are eligible for funds with the exception of the following: All raffle or dinner tickets; sporting events, athletic organizations, or scholarships; religious, fraternal, political, or booster club dues, subscriptions, or tuitions fees; payment in lieu of tuition, loan repayments, insurance premiums which name the organization as the beneficiary, or any other donation where an employee or an employee’s family member(s) receive a benefit.