NKSJ Group's Commitment to Compliance

The NKSJ Group aims to be a corporate group trusted by society by providing customers with the highest-quality services and absolute peace of mind. Toward this end, the Group conducts appropriate corporate activities in compliance with laws, other applicable rules, societal norms and corporate ethics, based on a constant recognition of insurance and financial services businesses' public mission and social responsibility.

NKSJ Group Basic Policy on Compliance (Overview)

NKSJ Group companies shall establish a compliance regime in accord with the following five policies.

1. Continually demonstrate a commitment to compliance-based management
   NKSJ Group executives and management personnel shall continually reiterate that compliance is always fundamental to the conduct of business. They shall also lead by example with concrete actions.
2. Act in accord with laws and regulations, societal norms, and corporate ethics
   NKSJ Group corporate officers and employees shall rigorously abide by all applicable laws and regulations and appropriately conduct business activities in accord with societal norms and corporate ethics. In doing so, they shall always voluntarily think, judge, and act based on the NKSJ Group Compliance Code of Conduct.
3. Establish systems and procedures to ensure the proper conduct of business operations
   To better provide services and peace of mind to customers, NKSJ Group companies shall establish systems and procedures enabling their personnel to properly conduct business operations on a continuous basis.
4. Promptly identify and organizationally resolve problems
   NKSJ Group companies shall make organization-wide efforts to promptly identify, share and resolve compliance-related problems that arise in the course of operations.
5. Disclose information proactively and impartially
   NKSJ Group companies shall endeavor to proactively and impartially disclose information regarding their management policies, finances and operations. They shall also endeavor to broadly communicate with society.

NKSJ Group Compliance Code of Conduct

Officers and employees of NKSJ Group companies conduct themselves in accordance with the following Code of Conduct, which is based on the NKSJ Group Basic Policy on Compliance.

1. Act with integrity and good sense in compliance with laws and regulations and company rules, and in accord with societal norms and corporate ethics.
2. Refrain from conduct unduly detrimental to the Company's interests.
3. Always act based on a clear distinction between public and private.
4. Act in accord with social norms without improperly giving or accepting money, gifts, hospitality or other personal benefits.
5. Adequately safeguard and refrain from divulging confidential information and customer information learned on the job.
6. Adequately safeguard nonpublic material information learned in connection with Company business and refrain from using such information in managing Company or personal assets or in other personal economic activities (insider trading).
7. Take appropriate action in response to other personnel's compliance infractions without overlooking or concealing them.
8. Respond organizationally and with firm resolve to antisocial forces that threaten the safety or order of civil society.
9. Treat people with respect in all situations, never discriminating against or harassing anyone.