Code of Business Ethics & Conduct

Striving To Be
a ‘Good Company’

Tokio Marine Insurans (Malaysia) Berhad (“TMIM”) 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. TMIM Code of Business Ethics & Conduct (“Code”) 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, we, the directors, officers and employees of TMIM, 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, 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 outlined via the Whistleblowing policy.

In TMIM, no one will be treated detrimentally because of his or her use of the hotline or cooperation with investigations. TMIM will not permit retaliation against anyone for using the hotline or cooperating with investigations. TMIM is also committed to protecting the anonymity of such persons to the maximum extent possible.

Non-compliance with this Code, 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 TMIM.

1. Compliance

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 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.

1.3 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.

1.4 Insider Trading
We shall not buy or sell the securities of any company 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.

1.5 Intellectual Properties
We shall respect and not infringe upon intellectual property rights of third parties, including copyrights, trademarks and patents.

1.6 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, or terrorist groups, it would result in encouraging illegal activities. In full recognition of our social responsibility, we, shall maintain a firm stand against all criminal forces.

2.2 Anti-Money Laundering and Counter-Terrorist Financing
We shall maintain 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 Gifts and Entertainment, Relation with Public Officials, etc.
We shall not accept money, goods and 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. 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 an 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.

4. Respect for Human Rights and the Environment

We shall respect the human rights of our customers, directors, officers, employees and all business partners, 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.
In compliance with applicable laws, rules and regulations as well as TMIM 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.

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.

Please visit Tokio Marine Group’s Sustainability Standard for a comprehensive understanding.