The Tokio Marine Group Policy for Management of Conflicts of Interest

Management of Transactions Involving Conflicts of Interest

Tokio Marine Group has formulated Policies for Managing Transactions Involving Conflicts of Interest and through compliance with these policies by directors, officers and employees works to manage conflict-of-interest transactions to ensure that clients' interests are not unduly harmed.

The Tokio Marine Group Policy for Management of Conflicts of Interest

1. Transactions Involving Conflicts of Interest

"Transactions Involving Conflicts of Interest" shall be defined as any of the following actions during the course of Tokio Marine Group's business activities.

1. (1)Transactions in which there is a potential conflict between the interest of a customer and the interest of Tokio Marine Group
2. (2)Transactions in which there is the potential for the interest of a customer to be harmed by the interest of another customer of Tokio Marine Group
3. (3)Transactions involving the use of customer information held by Tokio Marine Group without the consent of the customer (with the exception of transactions involving a Purpose of Use specified beforehand in accordance with the Act on the Protection of Personal Information in Japan or provisions of other laws and regulations applicable to Tokio Marine Group)
4. (4)Besides transactions specified in (1) to (3) above, transactions or other actions that especially require management from the perspectives of protecting customers of Tokio Marine Group and maintaining confidence in Tokio Marine Group

2. Structure for Managing Transactions Involving Conflicts of Interest

Tokio Marine Holdings, a holding company, uniformly controls matters concerning the management of conflict-of-interest transactions for Tokio Marine Group. To do so, Tokio Marine Group has established a structure that includes setting up a department that controls the managing of conflict-of-interest transactions at Group companies mentioned below as it appropriately manages conflict-of-interest transactions.

1. (1)Tokio Marine Holdings, Inc.
2. (2)Tokio Marine & Nichido Fire Insurance Co., Ltd.
3. (3)Nisshin Fire & Marine Insurance Co., Ltd.
4. (4)E. design Insurance Co., Ltd.
5. (5)Tokio Marine & Nichido Life Insurance Co., Ltd.

3. Methods for Managing Transactions Involving Conflicts of Interest

Tokio Marine Group manages transactions involving conflicts of interest through the following methods.

1. (1)Tokio Marine Group companies shall report beforehand to Tokio Marine Holdings on any intended transactions with a potential conflict of interest.
2. (2)When Tokio Marine Holdings determines that such reported transactions will unduly harm the interests of a customer or has the potential for such harm, it shall take action using the methods below.
   1. 1)A method that separates the department executing the relevant transaction and the department executing other transactions with the customer involved in the relevant transaction
   2. 2)A method that changes the conditions or methods of the relevant transaction or of other transactions with the customer involved in the relevant transaction
   3. 3)A method that properly discloses to the customer involved in the relevant transaction that there is the potential that the customer's interests will be unduly harmed along with the execution of the relevant transaction
   4. 4)A method that obtains the consent of the customer concerned for the use of customer information held by Tokio Marine Holdings and Tokio Marine Group companies along with the executing of the relevant transaction
   5. 5)A method that suspends the relevant transaction or other transactions with the customer involved in the relevant transaction
   6. 6)Any other method recognized by Tokio Marine Holdings as being necessary and appropriate

4. Verification of Management Structure for Transactions Involving Conflicts of Interest

Tokio Marine Holdings shall periodically verify the appropriateness and effectiveness of Tokio Marine Group's structure for managing conflict-of-interest transactions.