Anti-Bribery and Anti-Corruption Policy

1 Anti-Bribery and Anti-Corruption Policy Argo Group (the Company) is committed to acting with integrity in all of its business transactions and relationships. As part of that commitment, it is the Company's Policy to adhere to all applicable Anti-Bribery and Anti-Corruption requirements applicable to jurisdictions i n whi ch the Company operates, which include the UK bribery Act of 2010, the US Foreign Corrupt P racti ces Act (FCPA) and the bribery Act 2016. The basic principles of Company's Anti-Bribery and Anti-Corruption Policy are: the Company does not offer or pay bribes or f acilit at e pay ments to g overn ment of ficials o r company executives in order to obtain business or gain improper business advantages.

2 The Company does not of f er or pay bribes or f acilitate payments indirectly through agents, brokers, vendors or other third parties;. the Company avoids the appearance of offering or paying bribes through other means , s uch as the purchasing of entertainment and gif ts that do not comply with Argo Group's Gif t and Entertainment Policy ;. the Company maintains accurate financial books and records and does no t c onceal bribes o r other improper payments through off book arrangements;. the Company does not falsify its financial books and records and is committed to appropriately;. documenting all appropriate business payments including those for gifts and entertainment.

3 Personal funds must not be used to accomplish activity that is prohibited by this Policy ;. the Company maintains a zero-tolerance approach to bribery , in any form. In applying this Policy , the Company will: Take measures to actively prevent and guard against unethical or fraudulent activity, including the use of the Company as a medium for facilitating bribery and corruption ;. Provide a clear procedure so that key functionaries and employees may identify potential act s of bribery and corruption and, where appropriate, report the existence of such potential acts including any suspicious activity; and Page 1 of 5.

4 Anti-Bribery and corruption Policy V8/2020. Ensure that all levels of management and employees (Key Functionaries ) are adequately trained and aware of their responsibilities under this Policy and all applicable regulatory or statutory requirements. Background Anti-Bribery and Anti-Corruption requirements are contained in a combination of Bermuda, US, UK, international and local Anti-Bribery and Anti-Corruption laws and regulations with which the Company K ey Functionaries must comply. bribery is a criminal offence in most countries in which t he Company, it s af f iliates and its employees transact business and the corporate and individual penalties for violating anti - bribery and Anti-Corruption requirements can be severe.

5 The Company may also be exposed to regulatory action if it fails to establish and maintain appropriate systems and controls to eliminate corrupt pract ices. Theref ore, this Policy is intended to ensure that the Company addresses, monit ors, and manages it s exposure to bribery and corruption issues. Argo Group has zero-tolerance to bribery in any form. Authority, Responsibility and Accountability Argo Group Board Approve the Policy and any material revisions that are made to it;. Conf irm that a review of the Policy is performed on an annual basis;. Delegate to the CEO the day to day responsibility for the implementation and maintenance of t he Policy , including the development, implementation and maintenance of a supporting Procedure.

6 CEO. Report to the Company's Board as required or appropriate;. Designate Compliance and/or General Counsel to develop, implement, and maintain an appropriate control environment and related reporting systems;. Ensure that Compliance and/or General Counsel provides guidance on the P olicy as required and monitors compliance with this Policy and the supporting Procedure. Page 2 of 5. Anti-Bribery and corruption Policy V8/2020. Heads of Business Divisions, Business within the Divisions, and Corporate Departments Responsible for working with their respective Executives, Senior Management and all employees to promote and maintain awareness of the Policy and its standards.

7 Responsible as the first line of defense, for establishing procedures that are intended t o ens ure that all Key Functionaries are complying and continue to comply with this Policy ;. Immediately report any violations =of this Policy to the relevant Business Division's E xec ut ive , local compliance Officer and/or legal counsel, and the appropriate Group Compliance employee and/or General Counsel;. Provide timely and accurate information as required by the applicable procedures to the relevant Business Division's Executive, local Compliance Officer and/or legal counsel, and appropriate Group Compliance employee and/or General Counsel.

8 Ref er requests f or Policy and/or Procedure interpretation and/or application to the relevant Business Division's Executive, local Compliance Officer and/or legal counsel, and the appropriate Group Compliance employee and/or General Counsel. Compliance and/or General Counsel Support the development, implementation and maintenance of an appropriate control environment and related reporting systems;. Review the Policy and Procedure at least annually;. Provide appropriate guidance as requested or required;. Monitor compliance with the Policy and Procedure;. Report to the CEO, regarding the status of employee compliance with the Policy and the Procedure, as required or appropriate.

9 Maintain records of relevant correspondence, inquiries and investigations relating to this Policy . Page 3 of 5. Anti-Bribery and corruption Policy V8/2020. Policy Considerations Exceptions or Waiver None Revision Compliance and/or General Counsel shall review the Policy at least annually and recommend all necessary material revisions via the CEO to the Board in due course for its cons iderat ion and adoption. Adoption This Policy and any material revisions to it are required to be adopted by resolution of the Board. Page 4 of 5. Anti-Bribery and corruption Policy V8/2020. Ownership: Policy Owner(s). Chief Risk Officer Version Control: Version: Effective Date: Reviewed By: V11/2011 11/2011 Designated Legal Counsel V3/2016 5/2016 Chief Risk Officer & Argo Group General Counsel V4/2017 5/2017 Chief Risk Officer & Argo Group General Counsel V5/2017 08/2017 Chief Risk Officer & Argo Group General Counsel V6/2018 5/2018 Chief Risk Officer & Argo Group General Counsel V7/2019 5/2019 Chief Risk Officer & Argo Group General Counsel V8/2020 5/2020 Chief Risk Officer Document Governance: Implementation Approved by: Argo Group Board of Directors Approval Date: May 5, 2020.

10 Related Materials: Argo Group Anti-Bribery and corruption Procedure Argo Group Conflicts of Interest Policy & Procedure Argo Group Gifts & Entertainment Policy and Procedure Argo Group Code of Conduct and Business Ethics Page 5 of 5. Anti-Bribery and corruption Policy V8/2020.