CODE OF CONDUCT

Regulatory Compliance

It is our policy to operate exclusively in jurisdictions where we are licensed and we require the same standards from all of the entities that submit cases for pricing. LBFS is regulated in each state in which it holds a Life / Viatical Settlement Provider License.

Code of Conduct

Living Benefits adopted and maintains detailed, written employee guidelines and work rules governing employees, internal and external fraud monitoring, legal procedures, and computer technology.

Some of the key guidelines and principles followed both internally and externally are:

• Conduct business with brokers who have undergone background checks
• Protect privacy of all personal information
• Follow all applicable laws regulating the life settlement industry
• Operate on the principals of full disclosure and transparency
• Adhere to strict HIPAA compliance

Data Security

Living Benefits maintains strict policies for data security, data backup, and disaster recovery to protect its clients' information from external intrusion threats, hardware failure, and physical building failure.

Our network is secured using Microsoft technology and an internet firewall. All systems have anti-virus protection and software updates are kept current.

Our web application requires a secure login. Logins by non-Company users are closely controlled and access is restricted. Password changes and associated security protocol requirements are automatically mandated every 30 days.

Due to the nature of our business and the fact that we obtain personal information over the internet, we utilize secure http protocols and certificates to encrypt data.

Backup procedures:

• All internal applications are regularly backed up.
• All servers use hardware technology to limit exposure to disk failures.
• Backups are created for external, offsite storage.

Disaster recovery:

• A basic amount of hardware is also kept offsite for redundancy purposes.
• Backup media and other software media are stored offsite for an extra layer of protection.
• We test our server environment disaster recovery plan on a regular basis.