Compliance

Tokio Marine Group (hereinafter "the Group") defines compliance as "observing applicable laws, rules and regulations and internal regulations and conducting fair and equitable business activities within social norms" and thoroughly implements compliance in this manner.

Tokio Marine Holdings (hereinafter "the Company") has formulated the "Tokio Marine Group Basic Policies for Compliance" and the "Tokio Marine Group Code of Conduct". The Company has maintained Compliance System for the entire Group in accordance with the Policy and the Code. Also, the Company has built a structure to ensure Group-wide compliance by periodically monitoring the status of compliance within the Group; receiving reports from Group companies on important matters; discussing these matters among the Board of Directors, Management Meeting and the Internal Control Committee; and providing guidance and support about the activities of Group companies when necessary.
Group companies proactively undertake thorough compliance in accordance with the "Tokio Marine Group Basic Policies for Compliance", etc. In addition, Group companies have created compliance structures suited to the content of their respective businesses while reporting to the Company on the status of thorough compliance and important issues concerning compliance.

Compliance System for Tokio Marine Group

Tokio Marine Holdings Audit & Supervisory Board Members (Audit & Supervisory Board) ⇒ Board of Directors ⇒ Internal Control Committee / Management Meeting ⇒ Legal & Compliance Department, Individual Business Divisions ⇒ Indication of basic policies, guidance/administration/monitoring ⇒ Group Companies Audit & Supervisory Board Members (Audit & Supervisory Board) ⇒ Board of Directors ⇒ Compliance Committee (Tailored to actual conditions at each company) / Compliance Department ⇒ Reporting

Organizational Framework

The Group has set up departments to oversee compliance at each Group company. Group companies have established frameworks enabling organized responses for compliance. The frameworks include compliance committees that formulate compliance policies and measures, and check on the state of compliance implementation.

Compliance Manuals

Based on the "Tokio Marine Group Compliance Standards" formulated by the Company, the Company and Group companies have prepared their own compliance manuals and have made these manuals well known to directors, officers and employees.

Compliance Training

The Group nurtures an awareness of compliance while providing persons in charge of business operations with necessary knowledge about compliance through training on laws, regulations and internal regulations etc. with which directors, officers and employees must comply.

Evaluation and Improvement Activities (Including Assessments and Monitoring)

The Group prepares and implements various measures to ensure compliance . The Group monitors the effectiveness of these measures through self-assessments by each Group company and internal audits by the Company and Group companies.

Hotline System (Internal Whistleblower System)

The Group maintains internal and external hotlines for the purpose of whistleblowing to provide additional reporting methods beyond the supervisor in order to obtain information regarding any actual and suspected breach of compliance or other misconduct.
To ensure the integrity and effectiveness of the hotlines, the Group will not permit any retaliation or harassment against a whistleblower or any person who assists in an investigation due to their involvement in a report and/or investigation. Furthermore, the Group also makes every effort to preserve the confidentiality of the whistleblower.
In 2021, 287 whistleblowing reports were received through the hotlines (13% increase from the previous year). All of the reports were investigated appropriately and contributed to early detection, rectification and mitigation of the problems.

Declaration of Commitment to Compliance

Tokio Marine Group is committed to the continuous enhancement of its corporate value, with customer trust at the base of all its activities. Strict compliance is at the heart of our Corporate Philosophy. The Tokio Marine Group Code of Conduct is a compilation of important matters that must be strictly observed. We, the directors, officers and employees of Tokio Marine Group companies, promise to prioritize compliance in the conduct of business activities in accordance with the Code of Conduct.

Satoru Komiya
President
Group CEO (Group Chief Executive Officer)
Tokio Marine Holdings, Inc.