Basic Policy on Human Rights

As our Corporate Philosophy states, with customer trust as the foundation for all its activities, Tokio Marine Group (the “Group”) continually strives to raise corporate value. The foundation for implementing this Corporate Philosophy is respect for the human rights of all people, such as customers, society (including business partners and civil society organizations), employees, shareholders and investors, and future generations, and we are committed to respecting human rights across all of our business activities. The “Tokio Marine Group Basic Policy on Human Rights” (the “Policy”) is based on the Corporate Philosophy and Code of Conduct and outlines our approach to respect human rights throughout our business activities, including our entire value chain.

Each officer and employee (including temporary staff) of Tokio Marine Group companies is expected to act in line with this Policy to ensure that our business activities comply with the Group human rights commitment.

We also expect our business partners to support and practice the principles expressed in this Policy and aim to work together towards the promotion of respect for human rights.

Tokio Marine Group is committed to respect human rights as stipulated in the International Bill of Human Rights^*1 and the ILO’s Declaration on Fundamental Principles and the Rights at Work^*2. We also support international standards such as the United Nations Guiding Principles on Business and Human Rights and the Japanese government’s Guidelines on Respecting Human Rights in Responsible Supply Chains, and will base our efforts on these principles. We are also a signatory to the United Nations Global Compact and support its ten principles.

Tokio Marine Group respects human rights in its business activities, including insurance underwriting, investment and financing, and the provision of solutions, through the signing and supporting of various other international initiatives listed in the Appendix. We also endeavor to address human rights issues, where possible, through the provision of insurance products and solutions as well as investment and financing.

Tokio Marine Group shall comply with applicable laws and regulations in the countries and regions in which it operates. If requirements of the local laws and regulations are in conflict with internationally recognized human rights, we will seek ways to honor the principles of internationally recognized human rights while complying with local laws and regulations.

The Board of Directors of Tokio Marine Holdings are informed of the compliance status of this Policy and has overseeing responsibility of the Group’s human-rights-related efforts. The Executive Management and the Sustainability Committee deliberate on and determine policies and measures as executive bodies and promote the Group’s human-rights-related initiatives. Each department of each Group company promotes activities related to respect for human rights in a proactive manner and in cooperation with one another.

Tokio Marine Group strives to conduct appropriate human rights due diligence to identify, assess, prevent and mitigate, and account for negative human rights impacts related to its business activities. We shall also comply with country-specific laws and regulations related to human rights due diligence, wherever applicable to our operations. Where we identify that our business activities have caused or contributed to negative impacts on human rights, we endeavor to remediate such impacts through appropriate processes and by holding dialogue with relevant stakeholders.

Tokio Marine Group recognizes that environmental issues such as climate change and the loss of natural capital, as well as the inappropriate use of technology and artificial intelligence, may have impacts on human rights. With respect to environmental and social risks, we act in accordance with our Policy to Address Environmental and Social Risks, and with respect to the use of AI, in accordance with our Basic Policy for AI Governance, and strive to prevent, mitigate, remediate and provide remedy for negative impacts on human rights.

In order for Tokio Marine Group to protect customers and society from all forms of emergencies, it is important that employees respect the diverse values and work styles of others, find their work rewarding and work with enthusiasm with colleagues. It is also essential to gain trust from all people and society by always acting in a way to respect human rights. Tokio Marine Group shall comply with laws and regulations concerning working conditions, including working hours and wages. We provide a dynamic working environment that is both safe and healthy and we promote training and education for our employees. Therefore, the officers and employees of Tokio Marine Group are expected to respect human rights as set out in this Policy while their human rights are also subject to protection under this Policy.

Tokio Marine Group treats all customers fairly in the provision of its products and services and does not discriminate against any customer based on unreasonable grounds.

We strive to be trusted by all people and society by supporting customer and society in times of need. We strive not only to prevent and mitigate negative human rights impacts associated with our products and services, but also promote the human rights of all of our customers and contribute to an inclusive society by providing products and services to meet its needs for safety and security.

In compliance with applicable laws, rules and regulations as well as the Tokio Marine Group Privacy Policy, we shall safeguard private information and specific personal information, etc., including customers' information, and we shall not use such information except on a need basis to carry out our business operations, in order to avoid any breach of privacy.

Through initiatives such as the development of a human rights risk map, Tokio Marine Group recognizes that serious human rights violations may inadvertently arise in projects in which it is directly or indirectly involved through insurance underwriting, investment and financing, or the provision of solutions. Tokio Marine Group endeavors to consider environmental, social and governance (“ESG”) issues, including human rights, in its decision-making processes related to insurance underwriting, investment and financing, and the provision of solutions. Where the Group identifies that its business activities are causing or contributing to adverse impacts on human rights, it will take appropriate action as a Group to promote respect for human rights.

Tokio Marine Group aims to fulfill its social responsibility and achieve sustainable development together with its business partners.

Tokio Marine Group expects its business partners to support and implement the principles expressed in this Policy and the Tokio Marine Group Responsible Procurement Guidelines and aims to work together towards the promotion of respect for human rights.

Tokio Marine Group also strives to prevent the occurrence of slave labor and human trafficking in its own business and value chain (supply chain) and encourages various stakeholders to work towards addressing such issues.

Tokio Marine Group has established internal and external hotlines (whistle-blowing hotlines) where officers and employees of Group companies can report and consult on matters that may involve human rights concerns. Tokio Marine Holdings monitors the handling of the reports and provides support for the appropriate installation and operation of the whistle-blowing system, thereby establishing a mechanism that allows officers and employees of each Group company to report concerns without fear of retaliation.

Tokio Marine Group has also established grievance mechanisms that allow all stakeholders to report or consult on matters involving potential human rights concerns. Where negative human rights impacts are identified, we endeavor to remediate such impacts through appropriate processes and dialogue with relevant stakeholders.

We prohibit any disadvantageous treatment or retaliation against those who reported and those who cooperate in investigations because of such reports or consultations. In addition, we strictly manage the confidentiality of reports and consultations by being prepared to preserve the anonymity of complainants in appropriate circumstances and sharing information only to the extent necessary for effective investigations and corrective measures.

Tokio Marine Group will provide the necessary training and capacity building for the implementation of this Policy to the officers and employees of each Group company. We further endeavor to provide the latest information and tools related to human rights and foster a culture of respect for human rights.

Tokio Marine Group will continuously monitor the implementation of its Policy and make improvements as necessary to ensure its effectiveness. In addition, we regularly disclose our efforts to respect human rights both internally and externally to ensure transparency and accountability.

This Policy may be amended or repealed by the Board of Directors of the Company. Notwithstanding the foregoing, the General Manager of the Corporate Planning Department may approve minor amendments to the Policy.

This Policy was approved by the Board of Directors of Tokio Marine Holdings, Inc.

Tokio Marine Group has established a human rights due diligence (HRDD) framework based on the Tokio Marine Group Basic Policy on Human Rights, with reference to the Universal Declaration of Human Rights, OECD Guidelines for Multinational Enterprises, ILO Core Labor Standards, the UN Guiding Principles on Business and Human Rights, ISO 26000, SA8000 and other relevant international standards.

For Tokio Marine Group, HRDD is positioned as an ongoing, preventive and voluntary process to become a “Good Company” and to avoid or mitigate any negative impact of corporate activities on human rights. Based on the process outlined below, Tokio Marine Group conducted a human rights risk assessment in fiscal 2017, and again in 2022, with the assistance of outside experts and specialists.

With the construction consulting and engineering company ID&E joining the Group in February 2025 and reflecting the expansion and diversification of our business domains, the Group has revised its human rights risk map to ensure more effective management of human rights issues across the Group.

Based on the results, we will continue to prioritize and strengthen our responses to human rights issues of higher severity. The human rights risk map will be continuously reviewed in the future, taking into account changes in the business environment and ongoing dialogue with stakeholders.

To identify the human rights issues that must be prioritized, a preliminary screening was conducted across Group companies, taking into account human rights risks by country, region and line of business, as well as factors such as revenue size and the number of employees. This process allowed us to extract the Group companies considered to be at high risk. As a result, the scope of this human rights risk map now extends beyond non-life insurance, life insurance and engineering consulting to include the Group’s directly operated businesses, such as nursing care and manufacturing, as well as customers, projects in which we are involved and the value chain^*1.

The guidelines and methodologies used in preparing the human rights risk map are outlined below. Since the results incorporate an analysis that utilized external data, the map also includes potential or latent human rights issues that have yet to emerge.

Salient human rights issues were identified across each business segment’s operations, customers, projects in which we are involved and the value chain. We then assessed these issues for severity and likelihood and developed a human rights risk map. In line with the UN Guiding Principles on Business and Human Rights, we designated issues with higher severity as priority human rights issues and intend to consider ways to strengthen current initiatives.

For the prioritized human rights risks identified in STEP 2, we are implementing measures to mitigate these risks as outlined below. We will continue to strengthen our efforts, taking into account feedback from internal and external stakeholders.

For details of STEP 4, please see the section below on “Response to the Modern Slavery Act 2015 of the United Kingdom and Modern Slavery Act 2018 of Australia.”

In March 2024, we set up a hotline on human rights violations for external stakeholders of Tokio Marine Group. The purpose of this hotline is to establish a means to identify negative impacts on human rights and formulate a process to correct and remedy negative impacts in cases where human rights issues are of concern in the value chain (including the supply chain).

Whenever a negative impact on human rights comes to light, we will correct and remedy the matter by implementing appropriate procedures and engaging in sincere dialogue with the stakeholders involved. We prohibit any disadvantageous treatment or retaliation against relevant stakeholders and those who cooperate in investigations because of such reports or consultations. In addition, we strictly manage the confidentiality of reports and consultations by ensuring anonymity and sharing information only to the extent necessary for effective investigations and corrective measures.

Tokio Marine Group has now established a “Global Stakeholders Hotline,” operated by TSUHO Support Center Co., Ltd., for external stakeholders to submit their grievances and concerns relating to human rights violations. This hotline has been established in line with the UN Guiding Principles on Business and Human Rights, to establish an effective grievance mechanism for individuals and communities who may be adversely impacted.

Though the Global Stakeholders Hotline allows for anonymous submissions, Tokio Marine Group promises to protect the privacy of individuals providing information through the Global Stakeholders Hotline and prohibits retribution or retaliation of any kind towards information providers. If you agree to the “Hotline’s Scope” set forth below and Tokio Marines Group’s Privacy Policy, please use the link below to navigate to the Global Stakeholders Hotline and enter the Company Code for Tokio Marine Group. Please note that by entering Tokio Marine Group’s Company Code and providing information through the Global Stakeholders Hotline, you are agreeing to the Hotline’s Scope and Tokio Marine Group’s Privacy Policy.

Please note that in order to provide information through the Global Stakeholders Hotline, you must also agree to TSUHO Support Center Co., Ltd.’s Terms of Use and Privacy Policy, which you can will find in the Global Stakeholders Hotline site linked below.

Please refer here(List of Group Companies | Tokio Marine Holdings, Inc. (tokiomarinehd.com)) for information regarding other Tokio Marine Group entities, if you wish to contact a Tokio Marine Group entity for other matters.

With respect to group employees, we use whistle blower and hotline systems to capture employees’ opinions in an effort to realize a better workplace environment.

Tokio Marine Group has established internal and external hotlines (whistle-blowing hotlines) where officers and employees of Group companies can report and consult on matters that may involve human rights concerns. The Group provides its officers and employees with multiple contact points and reporting channel options including internal and external hotlines, as well as a company audit hotline. We prohibit any disadvantageous treatment or retaliation against relevant officers, employees and those who cooperate in investigations because of such reports or consultations. In addition, we strictly manage the confidentiality of reports and consultations by ensuring anonymity and sharing information only to the extent necessary for effective investigations and corrective measures.

Tokio Marine Holdings monitors the handling of the reports and provides support for the appropriate installation and operation of the whistle-blowing system, thereby establishing a mechanism that allows officers and employees of each Group company to report concerns without fear of retaliation.

Tokio Marine & Nichido, Tokio Marine Kiln and other Tokio Marine Group companies published a modern slavery statement in compliance with the UK’s Modern Slavery Act 2015. Meanwhile, Tokio Marine & Nichido and other companies submitted a modern slavery statement to the Australian government in compliance with its Modern Slavery Act 2018.

Tokio Marine & Nichido has been publishing its statement every year since 2016 under the Modern Slavery Act 2015 of the United Kingdom. Starting from 2020, the company also annually reports (registers) its modern slavery statement to and with the Australian government under the country’s Modern Slavery Act 2018. Tokio Marine & Nichido will continue to report its modern slavery statement without fail, and together with its employees and business partners, will implement initiatives to prevent slave labor and human trafficking.