Operating with Integrity

Business Ethics

HEI’s Corporate Code of Conduct establishes high ethical standards across our family of companies. The Code applies to all board members, executive officers, employees (including part-time), and third parties (e.g., vendors, suppliers, contractors) in their engagements with HEI.

All of us at HEI have a responsibility to know, understand and adhere to our Code of Conduct, company policies, and applicable laws and regulations. HEI strives to promote a culture in which employees feel comfortable raising concerns and reporting issues in good faith without fear of retaliation. We provide annual training on the Code of Conduct. We also provide several avenues for confidential, anonymous reporting of suspected violations, including through the company’s EthicsPoint platform. We have procedures for investigating reported concerns or suspected violations, and we do not tolerate retaliation against employees who report in good faith any ethics or compliance issues. Our Board of Directors reviews and approves the Code of Conduct as needed and reviews reports of potential violations with management on a quarterly basis.

Human Rights

Our Code of Conduct includes several components focused on respect for human rights. For example, the Code of Conduct outlines our zero tolerance policy with respect to human trafficking and forced labor; this policy applies to all those covered by the Code of Conduct, including vendors and contractors. In addition, the Code of Conduct describes our commitment to providing a work environment that is safe, dignified, productive and free of harassment and discrimination. We plan to further detail our commitment to and policies regarding human rights in future materials.

100%

OF ACTIVE EMPLOYEES ACROSS THE HEI FAMILY OF COMPANIES COMPLETED HEI CODE OF CONDUCT TRAINING AND ACKNOWLEDGMENT IN 2021

HEI’s Corporate Code of Conduct establishes high ethical standards across our family of companies.”

Corporate Code of Conduct

‘imi pono

to strive to be righteous

Read our HEI Corporate Code of Conduct

HEI Corporate Code of Conduct

Areas addressed by the Code include (not exhaustive):

Our Shared Responsibility and Commitment

Examples of Violations Resources and Reporting Avenues Anti-Retaliation

We Act in the Best Interest of Our Company and Our Customers

Protecting Confidential Information Protection and Use of Company Assets Conflicts of Interest

We Act with Honesty and Integrity

Fair Dealing, Antitrust and Anti-Tying Anti-Corruption and Anti-Bribery Anti-Human Trafficking

We Honor Our Legal Obligations

Insider Trading Financial Reporting Obligations Anti-Money Laundering, Anti-Terrorist Financing and Trade Sanctions

We Welcome Diversity and Foster a Productive Work Environment

Equal Employment Opportunity and Anti-Discrimination Anti-Harassment and Anti-Violence Alcohol and Drug-Free Workplace

We Care About Our Community and Neighbors

Environmental Management and Training Charitable Contributions Political Activity, Lobbying, Contributions and Endorsements