AMG maintains a strong corporate culture that promotes the highest standards of ethics and compliance for our business. Our Code of Business Conduct and Ethics (the “Code”) sets forth the important principles guiding the conduct of our employees, officers, and directors. The Code governs the management of conflicts of interest and corporate opportunities, prohibits any engagement in unlawful activity in conducting AMG’s business, and requires that all business matters be conducted in accordance with ethical standards and applicable laws. Employees certify, at least annually, that they have read and agree to comply with the Code. Employees are required to report violations of the Code, or of any applicable law, rule, or regulation to the Company. Reporting of any actual or suspected code violations, misconduct, or concerns may be done confidentially through an independent, third-party operated “whistleblower” hotline available 24/7 in applicable languages, or to the employee’s manager, Human Resources, or General Counsel and / or principal legal officer. AMG strictly prohibits retaliation in response to such reporting.

AMG takes seriously its responsibility to conduct its business in a manner that avoids conflicts of interest and the potential for improper influence. AMG’s Policy on Political Contributions and Other Restricted Payments (the “Policy”) requires full compliance in the conduct of AMG’s business with all political contribution, anti-bribery, and anti-corruption laws of the jurisdictions in which we and our Affiliates conduct business, including, but not limited to, the Foreign Corrupt Practices Act, the UK Anti-Bribery Act, and federal and state pay-to-play statutes and regulations. Under the Policy, employees cannot offer, or cause AMG to offer, any payment, gift, or contribution, or anything of value, including to elected officials or candidates for elective office of a federal, state, or municipal government entity, either directly or through intermediaries, for the purpose of obtaining or retaining business for AMG or our Affiliates, or gaining an advantage in the conduct of any business.

In accordance with the Policy, all employees must conduct business in an honest and ethical manner. AMG takes a zero-tolerance approach to bribery, corruption, criminal facilitation of tax evasion, and improper influence, and is committed to acting professionally, fairly, and with integrity in all business dealings and relationships where we operate. Any political contributions by certain employees to candidates for federal, state, and local office must be pre-approved and reported on a quarterly basis. All employees participate in mandatory annual anti-corruption training and are required to certify at least annually that they have read and agree to comply with the Policy. To avoid even the appearance of conflict with our Affiliate investment operations, AMG has adopted a strict policy that prohibits employees from trading in their personal accounts in any publicly traded security.

AMG’s Board of Directors has principal responsibility for oversight of, and is committed to upholding, our Code of Business Conduct and Ethics and our risk management framework; the majority of Directors have extensive background and experience in risk management. On a quarterly basis, the Audit Committee discusses with management and the Company’s independent auditors the Company’s risk management processes, including major risk exposures, risk mitigants, and the design and effectiveness of the Company’s processes and controls. Furthermore, the Audit Committee and the Board of Directors as a whole receive regular reports from management and our independent auditors on prevailing material risks and the actions being taken to mitigate them, including reports regarding the Company’s business and operations. Management also reports to the Audit Committee and the Board of Directors regarding enhancements made to our risk management processes and controls in light of evolving market, business, regulatory and other conditions, including those related to ESG factors, including privacy and data security. AMG has an internal audit function which reports quarterly to the Audit Committee of the Board of Directors. The following documents are available on AMG’s corporate website: Corporate Governance Guidelines; the Code of Business Conduct and Ethics applicable to all directors, officers, and employees; the Code of Ethics applicable to our Chief Executive Officer, Chief Financial Officer, and other senior financial officers; and the charters for the Audit, Compensation, and Nominating and Governance Committees.

Succession Planning

AMG has demonstrated the depth and effectiveness of its succession planning through a recent period of organizational evolution as the Company completed a generational transition to its current Chief Executive Officer, Jay C. Horgen. In May 2018, the Company announced that Sean M. Healey, the Company’s Chief Executive Officer and Chairman at the time, had been diagnosed with amyotrophic lateral sclerosis (a terminal motor neuron disease known as ALS), and initiated its long-term succession plan. In May 2019, our Board of Directors appointed Mr. Horgen, Chief Financial Officer at the time, as President and Chief Executive Officer, and Thomas M. Wojcik joined AMG as Chief Financial Officer. The approach provided continuity of leadership in a time of unexpected transition and drew on the strengths and experiences of the Company’s most senior executives. The independent Directors continue to serve as a source of strategic strength for the Company and for Mr. Horgen and the balance of the executive management team, bringing significant diversity in skills, experiences, and perspectives. The independent Directors and Mr. Horgen continue to focus on developing and expanding the senior management team, to maintain a breadth and depth of talent that ensures that AMG is well-positioned to continue to refine and execute against its strategy.