The Tokio Marine Group, which places customer trust as the foundation of all its activities, is implementing various compliance-related initiatives based on its belief that it is important to thoroughly implement compliance through its day-to-day business, with employees and agents maintaining high ethical standards.

The Tokio Marine 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. Additionally, the Company has formulated the Tokio Marine Group Code of Conduct that incorporates matters that directors, executive officers and employees should comply with from the perspective of compliance.

To thoroughly implement compliance as a Group, Tokio Marine Holdings has formulated the Tokio Marine Group Basic Policies for Compliance, which prescribes the role of the Company, its Subsidiaries and Others and the basic rationale regarding the implementation of compliance, and also prepares measures and policies for the entire Group. Subsidiaries and Others shall build compliance systems in a form suited to the content and scale of their respective businesses in accordance with the Tokio Marine Group Basic Policies for Compliance and shall report on important matters to Tokio Marine Holdings. Tokio Marine Holdings also deliberates and makes decisions on important compliance-related matters via the Board of Directors, Management Meeting and the Internal Control Committee, and when necessary, provides guidance and advice about such matters to its Subsidiaries and Others.

Tokio Marine & Nichido has also established a Quality Improvement/Compliance Committee, which has a majority of members from outside the company, that evaluates the establishment of compliance systems from an external perspective and checks, monitors and provides suggestions on the appropriateness of overall business operations. Tokio Marine & Nichido has appointed a Compliance Leader (CPL) in each production department who provides guidance on initiatives for compliance and fulfills a check-and-balance function, among other responsibilities. It also has appointed a Compliance Officer (CPO) in each region's business support department who fulfills a check-and-balance function with regard to production departments and supports the CPL. In this way, Tokio Marine & Nichido has built up a system for thorough compliance throughout a wide range of operations it conducts.

In the overseas Group companies, compliance is promoted primarily under the lead of the CPOs in the respective companies on the basis of undertaking proper business in accordance with the above policies and with respect for local laws and regulations.

Tokio Marine & Nichido proceeds with thorough compliance by all employees as important business activities in day-to-day business operations, particularly in sections in charge of production and claims services.

The Compliance Leader (CPL) assigned to each production department provides guidance on initiatives to production and claims services sections and fulfills a check-and-balance function with regard to business operations in each section through handling inquiries on individual matters as well as conducting compliance training for employees and agents.

The Tokio Marine Group has installed hotlines as a system for handling reports and consultation from employees and the management of Group member companies in the event a compliance-related issue has arisen or there is a likelihood of such an issue occurring. An external hotline is also established at an external law office so that the persons making such reports are able to select the hotline most convenient for them.

The Group keeps personal information on individuals making such reports strictly confidential and ensures that such individuals are not put in a disadvantageous position.

1. The Tokio Marine Group has prescribed the basic policies concerning responses to anti-social forces so that Subsidiaries and Others can resist anti-social forces and make concerted and uniform responses. Initiatives are being promoted based on the following basic concepts.

   • (1)To ensure it consistently undertakes fair management and widely contributes to the development of society as a good corporate citizen, the Tokio Marine Group shall sever all relationships with anti-social forces and forcefully repudiate any illicit demands made by them as a basic matter in the application of its management philosophy. In association with lawyers, police and other professionals, it will respond to anti-social forces in an uncompromising and organized manner.
   • (2)Subsidiaries and Others shall respond to anti-social forces based on the following measures.
     1. 1)Take action as a unified organization while ensuring the safety of directors, officers and employees;
     2. 2)Contact relevant external institutions (specialized in such matters);
     3. 3)Sever all known relationships, including transactions and repudiate any illicit demands;
     4. 4)Take legal action at either the civil or criminal level for any contingency; and
     5. 5)Prohibit backroom deals and access to capital.
2. Taking into consideration the basic policies for responding to anti-social forces, the Tokio Marine Group shall promote initiatives that include setting up controlling departments, establishing reporting and consultation rules and systems for when a problem occurs, and implementing training activities.