Recording Gifts and Entertainment
All gifts and entertainment valued at $10 or more are reportable. When practical, entertainment given or received and gifts given that are expected to exceed $100 require pre-approval from your Department Head or an executive officer designated by the Department Head. Third party invitations for entertainment hosted at locations outside of the local business location in which the outside party is paying some or all the cost of the trip (e.g. hotels, meals, entertainment, tickets to sporting events, etc.) require the written pre-approval of your EMC member. Transportation expenses should always be paid by the Company.

Employees do not have to report gifts and entertainment under the following situations:

• Entertainment given to New York Life agents and their guests - unless the employee's area is required to report the information for regulatory purposes.
• Business related gifts and entertainment provided by fellow employees or by the Company or department.
• Commemorative items such as an inscribed paperweight, plaque or crystal bowl received to commemorate a special event or a product/Company promotion.
• Gifts between employees which are purchased with personal funds.
• Entertainment including meals received at industry meetings if the department already paid an admission or attendance charge for the meeting.

You should also check with your manager to learn about any other standards specific to your department's operations.

Contract Negotiations
Vendors sometimes offer gifts or entertainment as an inducement during contract negotiations. It is inappropriate for employees to accept any gifts or entertainment during contract negotiations.

Charitable Donations
Charitable donations should be separated from business dealings. If you ask a customer or vendor to support a charitable organization, for example, by buying raffle tickets or donating goods for a charity event, make it clear that their donation will not affect current or future business dealings.

The United Way, the Company's primary corporate charity, collects contributions from the Company and its employees. We do not ask local businesses or vendors to contribute cash, goods, or services to support or enhance our United Way fund raising efforts.

Entertaining Public Officials
Laws regarding gifts and the entertainment of federal, state, or local public officials are complex and vary widely from state to state and locality to locality.

These various "gift" and entertainment laws generally prohibit or significantly restrict a person from giving things of value to public officials or employees. Items of value include entertainment (tickets to sporting events, golf green fees, etc.), travel, lodging, transportation, meals, and other tokens of appreciation.

For purposes of this policy, a government official or employee means any person at the international, federal, state or local level who is (1) an elected government official; (2) appointed by another government official; (3) an officer or employee of a government agency, authority, commission or board or any other entity that is created by statute or regulation; (4) compensated in any way through appropriated funds; or (5) an officer or employee of a corporation of which the government is at least a partial owner. It does not include outside consultants or independent contractors of a governmental entity.

To determine whether an employee is permitted to entertain a public official, New York Life requires that all gifts be pre-cleared for approval. To obtain pre-clearance, please call Brian Loutrel at (212) 576-7384. You should provide the specific names and titles of the officials, as well as complete details of the proposed entertainment and anticipated expenses. For example, if an employee wishes to take a New York City official to dinner, the employee must receive pre-clearance of the meal.

If you are working directly with the Office of Governmental Affairs in dealing with public officials, the Office of Governmental Affairs' representative will obtain the necessary pre-clearance from the senior officer responsible for governmental affairs.

Whether or not a gift is granted pre-clearance will depend on several factors, including the applicable gift law, the nature and value of the gift, the prior relationship with the public official, if any, and other circumstances surrounding the gift.

The Company will be asking employees to verify their compliance with these procedures annually, through the Conflict of Interest Questionnaire.

Purchasing
The Purchasing Division of the Corporate Services Department is responsible for acquiring merchandise such as equipment, supplies, and printed materials. Centralized purchasing results in considerable cost savings and ensures that the Company's purchasing policy is followed, (including bidding), and that appropriate financial and auditing controls are followed as well. This process also assures that the Company fulfills its responsibilities as a federal contractor, and as a member of the National Minority Supplier Development Council. Therefore, all purchases must be handled through the Chief Procurement Officer. The acquisition of computer systems is assigned to the Corporate Information Department.

Vendors soliciting directly from a department must be referred to either the Purchasing Division or the Corporate Information Department. These divisions also negotiate the return of rejected purchases to vendors.

Financial Transactions
Federal law strictly governs the financial transactions of publicly held companies-for example, some of the financial institutions with whom we do business. But as an employee, your own financial transactions-the sale or purchase of stock, financial interests in outside companies, and procurement of loans-can also be considered a reflection of New York Life. This is especially important if your job requires you to have access to sensitive, non-public information-"inside information"-about a company's current or future business transactions. We all must take care to avoid the appearance of impropriety by understanding the implications of financial transactions before they occur.

Insider Trading
What is insider trading? If you purchase or sell the securities of a public company while in possession of material, non-public information, or communicate such information to others who trade, you may have engaged in insider trading. The law in this area is complex and still developing.

Material information is the kind of news that would significantly affect the price of a company's securities or the decision of a person to buy or sell a company's securities. Though it is not possible to list every form of "material" information, information relating to the following is often deemed "material": business prospects; contract negotiations with a potentially significant customer; plans for acquisitions, mergers, buyouts, or changes in control; capital resources; financial condition and liquidity; contingencies; and status of control persons and management.

Any information which has not been disclosed to the general public is considered "non-public" information. Information is considered to be public when it has been widely disseminated; for instance, after it has been disclosed on radio or television; on the Dow Jones news wire or other news wire services; in national newspapers such as The Wall Street Journal or The New York Times; or as soon as documents are made available by the SEC, such as annual, quarterly, and periodic reports, proxy statements, or prospectuses.

It is the policy of New York Life to maintain the confidentiality of information received by New York Life personnel, and to prohibit the use of such information in any manner that would violate any applicable law or that could create an appearance of impropriety. Any employee of New York Life who becomes aware of any material, non-public information with respect to any company or the market for its securities is prohibited from taking any of the following actions with respect to such securities:

Effecting transactions in such securities for a personal account or for a Company account. A personal account is any brokerage account maintained by or for the benefit of an employee, or such person's "family member," including any account in which the employee or family member holds a direct or indirect beneficial interest, retains discretionary investment authority, or exercises a power of attorney. The term "family member" means an employee's spouse, child, or other relative, whether related by blood, marriage, or otherwise, who either (i) resides with, or (ii) is financially dependent upon, or (iii) whose investments are controlled by, the employee. The term also includes any unrelated individual whose investments are controlled and whose financial support is materially contributed to by the employee, such as a "significant other."

• Recommending, influencing, or soliciting transactions in such securities by any other person;
• Communicating such information to any person except individuals who may properly receive such information in connection with the performance of their responsibilities for New York Life.

If your securities transactions become the subject of scrutiny, they will be viewed after the fact and with the benefit of hindsight. Accordingly, before buying or selling any stock, bond, or other security of a publicly traded company that has a business relationship with New York Life of which you are aware, you should carefully consider how regulators and others might view the transaction in hindsight.

Federal securities laws authorize the imposition of criminal and civil penalties, including jail time and fines, on any person who buys or sells securities on the basis of material non-public information, or who discloses such information to another person who trades in the securities.

In addition to the penalties imposed by law, any infraction of Company rules on personal securities transactions will subject a New York Life employee to disciplinary action, which may include a warning, a reprimand, probation, suspension, a monetary penalty, demotion, or dismissal.

Other Personal Securities Transactions and Financial Interest
While the Company is considering the purchase or sale of any securities, no employee having knowledge thereof, directly or indirectly, shall purchase or sell or recommend the purchase or sale of the same securities until such time as the Company's requirements have been completed, or until consideration of the investment has been terminated. In the case of a public or private offering of securities, no employee shall purchase or sell or recommend the purchase or sale of any securities of the same corporation until such time as the Company's requirements have been completed or until consideration of the investment has been terminated.

No employee having responsibility for the approval or issuance of orders, contracts, or commitments for the furnishing of supplies or services by New York Life, or for the making of loans or arrangements for services by New York Life, shall:

• have a financial interest in any supplier or customer of New York Life, without first making a written report of the facts to the Committee on Conflicts of Interest and obtaining its approval; or
• fail to report in writing to the Committee on Conflicts of Interest any financial interest that an immediate family member of such employee may have in any supplier or customer of New York Life.

An employee shall promptly advise the Committee on Conflicts of Interest if the employee or any immediate family member:

1. acquires or maintains a financial interest (other than stock ownership) in any life insurance or health insurance agency, insurance brokerage firm, or any insurance consultant firm; or
2. acquires or maintains any financial interest in any mortgage loan correspondent of the Company or other mortgage banking concern;
3. acquires or maintains any financial interest in any investment banking firm, brokerage, or other firm engaged in the business of buying and selling securities, or
4. acquires or maintains any financial interest in any organization providing managed care services, such as Health Maintenance Organizations (HMOs), Preferred Provider Organizations (PPOs), and utilization management companies.

III. Representing the Company to the Public

Policy for Review of Public-Facing Communications
Corporate policy requires that Company information be communicated to the public in a manner that reflects our goals and objectives. Two corporate departments are involved in this process; the Office of Governmental Affairs and the Corporate Communications Department.

In order to minimize the possibility that one department or business unit may engage in public or governmental communications activity that - while beneficial to that business - may unwittingly affect another area, it is crucially important that senior managers and their staffs coordinate communications through OGA and CCD.

Office of Governmental Affairs
If you are asked to testify before or comment to a legislative or regulatory body, a federal or state agency, or a foreign government or international trade body, the content must be reviewed and approved by the Office of Governmental Affairs. Comments of this type are often posted on federal and state agency Web sites, and are there accessible to news organizations and others.

Corporate Communications
Corporate Communications plays an important role in preparing executives for interviews with news media. All individuals must pre-clear interviews with Corporate Communications. If you are asked by the news media to comment on Company business, contact Corporate Communications. They will advise you of steps to be taken. Content of speeches, lectures and articles (including any request for "endorsements") also must be approved in advance if you are doing so as a representative of the Company. Clearance by CCD of press releases and advertising content has always been - and continues to be - required.

New York Life encourages its employees to be actively involved in the civic affairs of the communities in which they live. When speaking on public issues, however, employees should do so only as individual citizens of the community and must be careful not to create the impression they are acting for, or representing the views of, New York Life.

Federal laws restrict any use of corporate funds in connection with federal elections, and there are similar laws in many states. Accordingly, it is against Company policy for any employee to do the following:

1. i. include, directly or indirectly, any political contribution that the employee may make on the employee's expense account. In general, the cost of fund raising tickets for political functions are considered political contributions,
2. use any Company property or facilities, or any time of Company employees, for political activity. Examples of prohibited conduct would include the use of Company secretaries to send invitations to political fund raising events.

Company contributions, direct or indirect, to any political candidate or party, or to any other organization that might use the contributions for a political candidate or party, must be approved by the Executive Management Committee. New York Life encourages employees to make voluntary contributions to candidates, either directly or through Political Action Committees.

IV. Safeguarding Important Information

Protecting Computer Resources
Safeguarding important information, including computer resources, electronic data, and paper files, is critical. It is the responsibility of all employees and agents to ensure that these critical Company assets are established, operated and maintained in a secure environment. While you are an employee of New York Life, and even thereafter, you are obligated to maintain the confidentiality of the Company's information. This requirement extends to any third party prior to any disclosure of Company information.

We rely heavily on computer resources to conduct business, and must be sure those resources are protected. Any information that is kept on file, electronically or on paper, must also be secured to protect the privacy rights of our customers and employees.

All computer systems, programs, and data must be secured from loss or damage. This protection includes procedures to prevent physical damage, but it is just as important to safeguard resources by ensuring their integrity and appropriate use.

Your manager is responsible for implementing and enforcing policies to protect our computer resources. But you are responsible for understanding these policies and the reasons for their existence.

Protecting our computer resources will prevent these potential problems:

1. Equipment damage resulting from hazards such as misuse or vandalism.
2. Inaccurate, damaged, or destroyed data caused by unauthorized access or attempted access to our systems.
3. Unauthorized access to proprietary, privileged, personal, or sensitive data.
4. Use of computer resources for purposes other than legitimate Company business.
5. Use of computer software of outside companies in violation of software license agreements and copyright laws.
6. Violations of privacy regulations, e.g., GLBA, HIPAA

Electronic Mail
Electronic mail (E-mail) is very common in business communications. It is faster than paper and provides more documentation than a phone call. But this efficient form of communication has opened some privacy and protection issues.

E-mail systems are considered one of the Company's computer resources, and should be protected in the same way as any other resource. Use E-mail primarily for legitimate Company business, and realize that all information stored, transmitted, or received on Company E-mail system is considered Company property.

If you need to send sensitive material via electronic mail, take care to route it only to people with a legitimate need to know. In addition, such sensitive information must be protected according to its classification level as defined in the NYL Information Classification Policy, e.g., Business Private information sent over the Internet must be encrypted. Employees must use only authorized New York Life e-mail systems when messages contain confidential or proprietary Company information. Since electronic messages can be used as evidence during legal proceedings, you need to use the same discretion in writing and sending E-mail as with any written documentation.

E-Mail Privacy
We make every effort to protect the privacy rights of E-mail users. However, these rights are balanced against our responsibility to protect sensitive data. Consequently, there is no expectation of privacy when using a NYL information resource. Authorized personnel will access an employee's E-mail to detect inappropriate use of confidential Company information or uncover abuse or improper use of the system. It may also be necessary to access a personal E-mail account to resolve a technical problem, or to retrieve electronic information of an employee who has left the Company.

Privacy
We have a long-standing commitment to ensure the privacy of personal information about agents, employees, and policyholders. Protecting this information is more than a Company policy; it is considered a corporate duty by the Privacy Protection Commission of the United States. Privacy guidelines for customers, agents, and employees help ensure that all personal and confidential information is safeguarded appropriately.

Customers' Rights to Privacy
The Company's files on applicants, policyowners, and insureds are confidential and may be seen only by agents and employees with a legitimate need for the information. Information will be disclosed to others only as authorized by the individual to whom it relates or in certain specific circumstances.

• If the individual who is the subject of the information authorizes it, we may release information to other life insurance companies where the individual has applied for life or health insurance or filed an insurance claim.
• If an applicant is seeking a large amount of coverage, we may need to share pertinent information with a reinsurance company, so that we can share the insurance risk with the reinsurer.
• We may report information to the Medical Information Bureau (MIB), which acts as an information exchange on behalf of member life insurance companies.
• If permitted or required by law, we may disclose information to government regulatory officials or law enforcement officials, without the individual's authorization.

Customers' Rights to Information
An applicant, policyowner, or insured can request information in our files. Medical information will only be disclosed to a designated physician. If an individual feels the information in Company files is inaccurate or incomplete, he or she may submit corrected information. Files will be supplemented or changed where warranted.

Some states have enacted laws based on the NAIC Insurance Information and Privacy Protection Model Act. These states require special compliance procedures. If your department regularly handles these matters, a list of these states will be given to you.

Agents' Rights to Privacy
Each Zone Office maintains a minimal amount of detailed information about its agents. This information may include agents whose sales warrant closer scrutiny or correspondence concerning a particular agent. The information is kept in a locked file and made available only to persons who need it.

Employees' Rights to Privacy
The information on file about you and other employees of the Company is controlled by the Human Resources Department. Their record-keeping practices are open to all employees and reviewed periodically to make sure they are ethical and lawful.

Your Employee Files
Your departmental file includes information such as attendance records, your latest performance evaluation form, and relevant memos or documents concerning your performance. Files are kept in locked cabinets to ensure confidentiality. A basic file is also maintained for each employee in the Human Resources Department. This file contains job-related forms and information dating from your job application. The file is confidential and access is limited to those who need the information.

We have specific policies controlling the release of employee information such as dates of employment, employment verification, salary data, or personal data to outside parties. These policies take into account your right to privacy, as well as the need to provide this information in specific cases, such as when you are applying for a loan or changing jobs.

Your Right to Information
If you want to inspect your own department file, see your manager. If you want to see your basic file, you need to call the New York Life Info Line at 888-513-INFO.

V. Complying with Laws

New York Life and all of its entities and employees must observe all laws and regulations of the United States and of the countries where we do business. As a large financial services company, we must be particularly alert to implications of conduct, in compliance with both the spirit and the letter of these laws.

U.S. and Foreign Laws

Our business operations and transactions must comply with domestic and foreign laws and regulations. Managers are responsible for reporting any events that may be questionable. If you know of, or suspect, an act that you think may be illegal, alert your manager to notify the Office of the General Counsel or do so directly.

Accurate Books and Records
In all of our operations, it is against Company policy for any employee to cause our books and records to be inaccurate in any way. Examples would include creating records that do not accurately reflect the true and complete nature of the transaction; or submitting expense account reports that do not accurately reflect the true nature of the expense; all such actions are strictly prohibited.

As with any Company transaction, do not intentionally withhold, misrepresent, manipulate, or alter any reports or financial filings, or other information to deceive any readers including, but not limited to management, regulatory agencies, any auditors, or others.

Sarbanes-Oxley Act
President Bush signed the Sarbanes-Oxley Act in 2002. The law applies to public companies. However, since 2002, New York Life has voluntarily chosen to comply with numerous sections of SOX, specifically section 302. But, we have also adopted sections of SOX that relate to auditor independence, corporate responsibility, and enhanced financial disclosures. We have also established a Financial Officers Code of Ethics.

The company receives management certifications that the financial reporting process and the internal controls have been evaluated, documented and validated. The Company has established a Financial Reporting Review Committee that reviews the results of this analysis and independently meets with the financial executives to review their certifications.

Improperly Influencing Government Officials
The Foreign Corrupt Practices Act also prohibits making or offering a payment to a representative of a foreign government for the purpose of influencing that government's action or obtaining favorable treatment. The payment may be direct or indirect, and can be in many forms, including cash, stocks, property, or services.

In certain countries, it is usual and customary to make nominal payments or tips to government employees to expedite performance of legitimate duties. Although every effort should be made to eliminate or minimize such payments, they may be made provided the department head is assured in writing that:

• the government action or assistance sought by the Company is legal and proper,
• the payments are customary in the country in which they are to be made, and
• there is no reasonable alternative to making such payments.

Such payments must be recorded on the books and records of the appropriate department.

International Boycotts
The United States Government must be notified if New York Life participates in, or is asked to participate in or cooperate with, an international boycott. When a business agrees to participate in a boycott, they agree as a condition of business to refrain from:

• doing business with or in certain countries, or with people from certain countries;
• doing business with any United States persons engaged in trade with certain countries;
• doing business with companies whose ownership or managers are a particular nationality, race, or religion;
• selecting or retaining corporate directors who are individuals of a particular nationality, race, or religion; and
• employing individuals of a particular nationality, race, or religion.

The U.S. Treasury Department periodically publishes a list of countries known to participate in boycotts. When the Company files its taxes, we must complete an International Boycott Report, telling the government whether or not we have operations in any of those countries which participate in boycotts. Countries who participate in boycotts are not allowed to purchase life insurance policies and annuities without being disclosed on the Boycott Report.

Conflicts of Interest / Compliance Questionnaire
The Conflicts of Interest/Compliance Questionnaire is used to formally track activities that relate to compliance with laws and regulations. Directors, executive officers, appointive officers, and certain employees are required to file these forms annually. These questionnaires include information about:

• events that may be considered questionable under the laws of the United States or a foreign country in which we do business,
• payments made on behalf of the Company to employees or officials of foreign governments,
• information that must be disclosed on the International Boycott Report,
• activities that may indicate a conflict of interest, and
• securities trading activity that may conflict with laws or regulations.

Questions concerning reporting requirements should be directed to the Office of the General Counsel.

Antitrust Compliance
Antitrust laws are designed to encourage free, fair, and open business competition. New York Life is strongly committed to these principles and to compliance with both the letter and spirit of all federal and state antitrust laws.

The most important federal antitrust law, and the one most likely to have an impact upon your activities for the Company, prohibits competitors from taking joint action to restrain competition. Some examples of the types of joint action prohibited under the antitrust laws are agreements to fix prices, to divide insurance markets (geographically or by line of business) or to refuse to do business with (i.e., "boycott") third parties. Other federal and state antitrust laws also prohibit a company from abusing a dominant market position, prevent certain unfair or deceptive commercial acts and practices and bar unethical business conduct.

When competitors agree to take joint action affecting competition they are engaged in conduct that raises significant antitrust risk, both for themselves and for the Company. Over the last several years, the insurance industry has been the focus of several antitrust investigations, and several individuals working in the insurance industry have served jail sentences for violating the antitrust laws. Insurance companies have also paid millions of dollars in civil penalties for antitrust violations.

Agreements among competitors to restrain trade often begin with an exchange of competitive information by company representatives, followed by a decision by the competitors to follow a joint course of conduct. While an exchange of information with a competitor, standing alone, is not necessarily unlawful, because such conduct presents a significant degree of antitrust risk the Company has created guidelines concerning the circumstances in which such exchanges should occur. These guidelines should assist you in recognizing and avoiding potential antitrust dangers whenever any exchange of information with a competitor is contemplated. However, these guidelines cannot cover every situation, and ultimately every Company employee must utilize his or her own good judgment. Whenever you have any questions, concerns or doubts regarding whether your conduct may raise antitrust risk, you should contact Rich Taigue at (212) 576-4490 or David Harland at (212) 576-4985 in the Office of General Counsel before you act for further guidance.

Violators of the antitrust laws are subject to civil and criminal penalties, including fines and jail sentences. Violators of the Company's antitrust guidelines are also subject to disciplinary action, including termination of employment.

Trade and Professional Association Activity
Trade and professional association activity present a special issue under the antitrust laws. While such activity offers opportunities for competitors to formulate legitimate joint positions on issues of common concern, because, by definition, a trade or professional association assembles a group of competitors to work together on common issues for their mutual benefit, and because the antitrust laws are designed to promote competition, not cooperation, among competitors, association activity can also present significant antitrust risks. In addition to the risk of actual conduct that violates the antitrust laws, the nature of trade and professional association activity can at times cause legal conduct to appear to be suspect under the antitrust laws. For this reason, the Company has developed antitrust guidelines specifically addressing conduct at trade and professional association meetings and functions to assist you in complying with the law.

While agreements with competitors pose the greatest risk under the antitrust laws, another type of agreement – agreements between employees and agents – can also raise antitrust risks in some circumstances. It is important to remember that all New York Life agents (except for certain inexperienced agents who are known as Training Allowance Subsidy ("TAS") agents) are independent third parties, not New York Life employees. The antitrust laws require that independent third parties be permitted to make certain of their business decisions independently, free from the control of New York Life.

Intellectual Property Protection
The Company's intellectual property is an extremely valuable asset and needs to be properly protected. At the same time, the Company respects the intellectual property interests of third parties when conducting its business. Intellectual property includes, but is not limited to, trademarks, copyrights, patents, trade secrets and business and customer information.

The Company policy is to fully protect its intellectual property. Protection should include filing for copyright, trademark or protection with the appropriate governmental agency and ensuring that a properly drafted and executed nondisclosure agreement be in place prior to the disclosure of confidential Company information. For guidance regarding the proper use and protection of copyrighted material, trademarks, patents or trade secrets, contact the Office of General Counsel. Also, to ensure that the Company's confidential information is protected before disclosure to third parties, the Office of General Counsel will provide appropriate guidance and nondisclosure agreements.

As it expects its own intellectual property to be respected and not misused, at the same time, the Company respects the same intellectual property rights and interests of third parties.

More specific information regarding copyrights and software copying:

Copyright Compliance and Software Copying.
United States and international copyright laws prohibit the copying, distribution, use, and display of a copyrighted work without the prior permission of the copyright owner except in very limited circumstances generally referred to as fair use. These copyright laws and restrictions apply to all third party written, audio and visual works as well as computer software, and extend to the making of derivative works or compilations of any copyrighted material.

The Company policy is to abide by all applicable copyright laws and to observe the terms and conditions of any license agreements to which the Company has agreed. Generally, computer software used by our employees is copyrighted property of the respective licensor, and the Company does not have the right to make copies of that software except for backup purposes. This includes not only the substantial software programs the Company may license, but also the smaller, so-called "shrink wrap" programs such as word processing, spreadsheets, and data management programs.

Company policy is to license a sufficient number of programs to provide for the legitimate requirements of all of our employees. For example, if a unit of the Company has six word processors all using their equipment simultaneously, they should have six word processing programs. They should not simply acquire one word processing program and make five copies for the others.

Copyright laws and Company policy prohibit individuals from making copies of Company licensed programs for personal, non-work related, use.

Consultants
All consultants New York Life retains must abide by the same code of conduct as our employees. It is the responsibility of any Company employee retaining a consultant for any purpose to make sure that each consultant is aware of our Corporate Policy Guidelines and Standards of Business Conduct and abides by all of their provisions. Also, each consultant must execute an appropriate nondisclosure agreement prior to being provided Company confidential information or being given access to any Company computer system or computerized data. The Office of the General Counsel will assist in providing guidance and developing appropriate nondisclosure agreements.

We include a letter outlining our expectations with our consulting agreements and contracts.

VI. Getting Help

Your Internal Support Network
Situations where integrity is questioned are usually emotional and personal, and it can be difficult to be objective. In addition, laws and regulations concerning ethical issues are often complex and subject to interpretation. This is why we maintain an internal staff with the expertise to monitor, intervene, and interpret these difficult issues.

Reporting Concerns about Accounting and Auditing Matters

Any Company employee may report good faith concerns regarding accounting, internal accounting controls or auditing matters at New York Life or its subsidiaries ("Accounting Concerns") to the management of the Company without fear of dismissal or retaliation.

The Company's Integrity Manual requires all employees to immediately report situations that appear to be unlawful or unethical to their supervisor or department head. If an employee is not comfortable raising an Accounting Concern with an immediate supervisor or department head, they should contact other internal staff, including the Corporate Ombudsperson, Corporate Compliance and Corporate Audit Departments.

To facilitate the reporting of Accounting Concerns in situations where all these avenues of communications have been exhausted, the Company's Audit Committee has established procedures for (1) the receipt, retention and treatment of Accounting Concerns and (2) the confidential, anonymous submission by employees of Accounting Concerns.

The Company's employees may submit Accounting Concerns on a confidential and/or anonymous basis to the Audit Committee through the Office of the Secretary via telephone, facsimile or regular mail. Confidentiality will be maintained.

Corporate Office of Business Conduct
The Corporate Office of Business Conduct makes sure that our policies and standards are ethical, and that all our employees and agents are aware of those standards. It conducts training, audits, surveys, and other programs, and works with the Human Resources and Agency Departments to develop formal training in ethical sales practices.

Brian Loutrel (212) 576-7384

Corporate Ombudsperson
The Corporate Ombudsperson provides a channel for employees to raise and discuss known or suspected illegal or unethical business conduct, without fear of reprisal. The office also provides and suggests alternatives for employees and agents to resolve problems informally.

Interpersonal conflicts, work disputes, harassment, or any issue that cannot be resolved through normal channels may be brought to the Ombudsperson, who will strive to discuss issues and provide assistance confidentially. The Ombudsperson is objective and neutral, and considers the rights and interests of all parties with the goal of achieving a fair, win-win outcome.

Corporate Compliance Department
Corporate Compliance ensures that our business standards incorporate the best practices of the financial services industry. Its duties include overseeing the proper screening of prospective agents; contracting and licensing of agents; monitoring sales data to be sure we are operating within the letter and spirit of the law; reviewing advertising and sales materials; monitoring customer complaints to be sure they are promptly followed up and resolved; maintaining and overseeing the Company's anti-money laundering and privacy programs to ensure that business units comply with appropriate regulations; and routinely reviewing operations for compliance with applicable regulations.

Corporate Audit Department
The Corporate Audit Department provides reports to the Audit Committee of the Board of Directors on the results of its audits, examinations, and investigations of the financial operations of the Company and its subsidiaries. The Department supports management by performing independent appraisals of the adequacy and effectiveness of the system of internal controls which safeguard assets and ensure the accuracy of financial reporting.

Complaint Review
Complaints are a vital source of information for us about the quality of our products and services and the way they are delivered. In handling a complaint from a customer, we first seek to resolve the complaint fairly and quickly. We also try to identify and resolve any general or systemic problems which could lead to further complaints.

The Complaint Review Division is part of the Corporate Compliance Department. They resolve complaints according to a procedure that ensures prompt resolution and compliance with laws and regulations.

Office of the General Counsel
The Office of the General Counsel (OGC) provides legal advice to the Company and its business units and profit centers, and oversees subsidiary legal operations. OGC is staffed with practitioners with expertise in insurance, litigation, securities, antitrust, bankruptcy, employment, intellectual property, human resources, and corporate governance.

OGC's primary goals are to: support the Company's business objectives in a complex, legal and regulatory environment; and limit legal risk in an efficient and cost-effective manner consistent with overall corporate strategy.

Special Investigation Unit
The Special Investigation Unit (SIU) of the Corporate Audit Department is an independent investigative unit responsible for ensuring that all allegations and suspicions of fraud are investigated promptly and discreetly. The SIU will conduct any type of authorized and legal inquiry. Employees should report suspicions of fraud either to management, or on a confidential and anonymous basis to the Corporate Ombudsperson or to the Special Investigation Unit.

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