The Tokio Marine Group is committed to the continuous enhancement of its corporate value, with customer trust at the base of all its activities. We strive to be a ‘Good Company’ that lives up to the trust placed in us. The Tokio Marine Group Compliance Code of Conduct sets forth ethical standards that are essential for translating this corporate philosophy and our efforts to be a ‘Good Company’ into action. It shall be given the highest priority in all aspects of our business operations and activities.
Based on this Code of Conduct, we, the directors, officers and employees of the Tokio Marine Group companies, will obey applicable laws, rules and regulations and internal rules. Having this in mind, we will conduct fair and equitable business activities within social norms. In order to conduct our business in a fair manner, we shall strive to understand the applicable rules and fully comply with them.
If we discover non-compliance with this Code of Conduct, applicable laws, rules, regulations or internal rules, we shall immediately report and discuss it with our immediate supervisor. If we determine that our ordinary reporting line is not appropriate, we shall use the hotline.
In the Tokio Marine Group, no one will be treated detrimentally because of his or her use of the hotline or cooperation with investigations. The Tokio Marine Group will not permit retaliation against anyone for using the hotline or cooperating with investigations. The Tokio Marine Group is also committed to protecting the anonymity of such persons to the maximum extent possible.
Non-compliance with this Code of Conduct, applicable laws, rules and regulations and internal rules are subject to appropriate action, including investigation, corrective action, reporting to the supervising authorities, disciplinary action against parties concerned and measures against recurrence, in accordance with the internal rules of each Tokio Marine Group company.
We shall comply with applicable laws, rules and regulations and internal rules, engage in free and fair competition and conduct fair and equitable business activities in conformity with social norms.
- 1-1 Compliance
- We shall strictly comply with applicable laws, rules and regulations and internal rules.
- 1-2 International Rules and Local Laws
- The rules which we must obey are not restricted to those applicable in Japan. We shall obey international rules and local laws, rules and regulations in the countries where Tokio Marine Group companies operate. We shall also respect the traditions and cultures in such countries.
- 1-3 Free and Fair Competition
- We shall conduct our business in compliance with antitrust, competition and free trade laws. We shall not undertake any action that hampers free and fair competition, including collusion and cartel formation. We shall abstain from any act falling under "unfair trade practices" such as overreaching. We shall be mindful of regulations applicable to the activities of trade associations.
- 1-4 Conflicts of Interest
- We shall not tolerate any action pursuing our personal or a third party's interests against our respective company's legitimate interests
- 1-5 Insider Trading
- We shall not buy or sell the securities of any company (including not only Tokio Marine Holdings, Inc. but also other companies; the same applies hereinafter) while in possession of material information regarding the subject company prior to the publication of said material information in violation of securities related laws, rules or regulations. When material information regarding any company comes into our possession, we shall not pass said material information to any other person unless it is necessary for the performance of his/her duties, or recommend any other person to sell or buy the securities of the company prior to the publication of said material information.
- 1-6 Intellectual Properties
- We shall respect and not infringe upon intellectual property rights of third parties, including copyrights, trademarks and patents.
- 1-7 Working Environment
- We shall comply with labor-related laws, rules and regulations and maintain a safe and proper working environment.
2. Social and Political Issues
We shall maintain proper conduct in social and political activities.
- 2-1 Criminal Forces
- If we succumb to criminal forces, including, but not limited to, criminal organizations, sokaiya (professional extortionists at shareholders’ meeting) or terrorist groups, it would result in encouraging illegal activities. In full recognition of our social responsibility, we, together with all Tokio Marine Group companies, shall maintain a firm stand against all criminal forces.
- 2-2 Anti-Money Laundering and Counter-Terrorist Financing
- As a corporate group operating globally, in order to fulfill our responsibility to the international community, we shall, by maintaining an internal control framework, endeavor to prevent our business operations from being exploited for the purpose of money laundering, terrorist financing or the proliferation of weapons of mass destruction.
- 2-3 Political Activities, Political Funding
- We shall comply with applicable laws, rules and regulations regarding public elections, political activities as well as political funds and donations, and we shall always maintain our posture toward fairness.
- 2-4 Gifts and Entertainment, Relation with Public Officials, etc.
- We shall not accept money, goods or other inappropriate or unlawful profits by taking advantage of our position. Also, we shall not accept or give any gifts or entertainment which are illegal or not considered reasonable by social standards.
In addition, we shall not allow any improper gifts, entertainment, benefits, or other advantages to a public official or to a person who holds a status equivalent thereto ("Public Officials, etc.")
3. Appropriate Actions of and High Transparency in Management
We shall take appropriate management actions and strive to realize a high standard of transparency in our management.
- 3-1 Appropriate transaction.
- We shall maintain sound relationships with clients and engage in appropriate and fair transactions.
- 3-2 Public Disclosure
- Appropriate disclosure of management information is also very important from the perspective of enhancing customer trust. In order to contribute to our shareholders’, investors’ and customers’ informed decision-making, we shall endeavor accurate and timely disclosures of information, including information submitted to regulatory authorities.
- 3-3 Accurate Information
- In order to make accurate and timely disclosures of information, we shall endeavor to create and manage a accurate records of management information. We shall cooperate fully with internal and external audits and inspections.
- 3-4 Confidential Information
- In accordance with applicable internal rules, we shall protect the confidentiality of nonpublic information and not disclose such information to anyone who is not authorized to receive it. In addition, we shall not use any such information for the benefit of anyone other than Tokio Marine Group companies.
4. Respect for Human Rights and the Environment
We shall respect the human rights of our customers, directors, officers, employees and all other people, and respect the global environment in all of our activities.
- 4-1 Anti-discrimination
- Human rights are values widely recognized around the world, and we shall never tolerate any discrimination on grounds of sex, age, profession, nationality, race, thought, creed, religion, social status or birth as well as any act constituting an infringement of human rights.
- 4-2 Anti-harassment
- We shall never tolerate sexual or any other kind of harassment or intimidation.
- 4-3 Private Information and Specific Personal Information, etc.
- 4-4 Protection of the global environment
- Acknowledging that the protection of the global environment is an important responsibility, we shall comply with applicable laws, rules and regulations, and respect the harmonization with and the improvement of the global environment in all of our activities.