Fit and Proper Policy

Whistle-Blowing Policy

All staff at Tokio Marine Kiln (“TMK”) and at any third party are entitled to carry out their duties in an environment that is both ethical and compliant with legal and regulatory requirements. If anyone becomes aware of or has a reasonable suspicion that:

 they are being requested or required to be involved in any dishonest, unlawful or improper action; or  any other member of staff, customer, agent, broker or supplier is behaving in a dishonest, unlawful or improper manner then they have the right to raise their concerns, suspicions or complaints, in confidence, with their line manager, the Group Company Secretary & Head of Legal Services, Head of Compliance, or any other member of senior management such as the Group Chief Executive or Chief Underwriting Officer. (Switchboard number: 0207 886 9000) This can be done anonymously.

The above officials shall investigate fully any complaint or concern and take appropriate remedial action.

Examples of the type of behaviour that could be the subject of such a complaint would include being aware that:

 improper or unlawful payments are being paid by a supplier to a member of staff;  a member of staff is behaving dishonestly e.g. falsely claiming expenses;  inaccurate or improper book entries are being made in accounting records;  an individual is ignoring regulatory requirements; or  there is unfair treatment of TMK customers.

Where a person obtains information or other material during the course of business based upon which they know or suspect, or have reasonable grounds for knowing or suspecting, that another person is engaged in money laundering or fraudulent activity, they are under a legal obligation to notify without delay the Head of Compliance. The Head of Compliance, who also acts as the Money Laundering Reporting Officer, will then take steps to notify the relevant authorities.

If a person has concerns that management has failed to address properly the concern or complaint raised, or that such concern or complaint cannot be raised directly with management, then they may raise such issues with the Chairman of the TMK Audit & Risk Committee, Richard Bennison, who is the TMK Whistle-Blowing Champion. He can be contacted by email ([email protected]) or by post (Richard Bennison, Tokio Marine Kiln, 20 Fenchurch Street, London EC3M 3BY).

Where the person considers the nature of the concern is such that it cannot be dealt with within TMK or by Richard Bennison, then they can contact the Tokio Marine Holdings internal hot line by telephone: 001-81-90-7403-4998; by email: [email protected] or by post: Internal Control Dept (Hot- 1 of 3 line), Tokio Marine Holdings Inc, Tokyo Kaijyo Nichido Building Shinkan 14F, 1- 2-1 Marunouchi, Chiyoda-ku, Tokyo, 100-0005, Japan.

Concerns may also be reported directly to the PRA or FCA via their Whistle- Blowing services whether or not a concern has been raised with TMK under this Policy. Further details are available at www.bankofengland.co.uk and www.fca.org.uk.

2 of 3 Anyone who raises a concern under this Policy will be protected from suffering detriment, bullying or harassment from TMK staff, provided that the disclosure of information is made in the public interest, the person making the disclosure believes it to be true and it is not made for personal gain. Any person found to be bullying or harassing another for whistle-blowing will be dealt with via TMK’s Dignity At Work Policy and Disciplinary Procedures.

If the nature of the complaint relates to sexual harassment, bullying, drug or alcohol abuse, racial or sexual discrimination then the Group Head of Human Resources should be contacted in the first instance.

December 2016

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