MS&AD Insurance Group Compliance Basic Policy

Japanese

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The MS&AD Insurance Group has established a Basic Compliance Policy as follows.

MS&AD Insurance Group Compliance Basic Policy

The MS&AD Insurance Group positions compliance as one of the foremost priorities in the management of the Group. We have adopted the following policies to establish a structure in which all of our officers and employees aim to achieve compliance, with a constant awareness of our corporate social responsibility.

1. Basic Policy

(1)
We intend to achieve our mission by ensuring compliance in every aspect of our corporate activities and by establishing corporate ethics.
(2)
We define compliance as "taking sincere, fair, and proper actions to respond to the expectations and requests of society, by complying with all laws and regulations related to our corporate activities, relevant guidelines issued by competent government agencies, and regulations of the holding company and Group companies ("laws and regulations, etc.").”

2. Development of Compliance Structure

(1) Development of systems

(i)
We will develop a system under which important compliance matters and breaches of relevant laws and regulations are appropriately reported to Board and senior management.
(ii)
We will manage compliance matters in an integrated manner, establish a department that enforces and monitors compliance, and give the department the authority needed to function the compliance structure effectively.
(iii)
We will develop reporting and consulting systems - for examples when our officers and employees identify any compliance-related misconduct and breaches of laws and regulations.

(2) Enforcing compliance

(i)
We will create a Compliance Manual setting out specific guidelines for compliance and will become fully familiar with it.
(ii)
We will develop and implement an annual Compliance Program as a specific plan of action and practice compliance accordingly.
(iii)
We undertake training and inspections to ensure compliance.
(iv)
We will immediately correct any inappropriate behavior related to compliance and analyze the causes to prevent a recurrence.

3. Code of Conduct for Officers and Employees Concerning Compliance

(1) Faithful conduct

(i)
We will comply with laws and regulations, etc., and if we discover any behavior with the potential to break laws and regulations, etc., we will have the courage to point out the behavior and correct it in cooperation with related persons and authorities where necessary.
(ii)
When considering an action, we will ask ourselves if the action is ethical, if we can explain the action to our customers, friends and family with confidence, and if the action will preserve confidence in the MS&AD Insurance Group and its brand.
(iii)
We treat every person faithfully, fairly, and appropriately in every situation.

(2) Conduct to ensure that corporate activities are appropriate

(i)
We will not engage in unfair trade, such as restricting competition through collusion or acquiring unfair benefits by abusing our position.
(ii)
We will protect our intellectual property rights and will not infringe on the intellectual property rights of others.
(iii)
We will diligently manage customer information we obtain in the course of our work and use such information only for specified approved purposes.
(iv)
We will be resolute in dealing with anti-social forces and will not accept any unjust, unlawful or unethical demands.
(v)
We will appropriately manage conflicts of interests to ensure that our customers' interests are not compromised unfairly.
(vi)
We will ensure that transactions are fair, for instance when we do business within the Group or form a business alliance.
(vii)
We will ensure that our management is transparent, by disclosing information appropriately on a timely basis.
(viii)
We will not engage in insider trading (trading in stocks, etc. using important undisclosed information).
(ix)
We will appropriately manage assets, important information, and trade secrets, etc. of the Group companies.
(x)
We will not seek personal benefits by making use of our position in business.

(3) Respect for Human Rights and Creating a Positive Working Environment

(i)
We respect human rights and will not discriminate or harass people based on race, nationality, gender, age, profession, region, faith, disability, or other elements.
(ii)
We will create a safe and comfortable working environment.

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