Compliance Basic Policy
We formulated the Compliance Basic Policy and "MS&AD Insurance Group Compliance Basic Policy" which is compliance criterion of the Basic Policy. Based on this Basic Policy or each policy, we and MS&AD insurance companies work positively to develop thorough compliance. All officers and employees carry out our social responsibility with responding to confidence of all the stakeholders including customers through the corporate activities based on the high ethical sense without failing to comply with laws and company internal rules.
Compliance Promotion Structure
The Company has formed Quality Improvement and Compliance Committee, as one of the task-specific committees under the Board of Directors, to monitor as well as discuss and make necessary adjustments in the compliance structure. For important matters related to compliance, Quality Improvement and Compliance Committee reports to the Board of Directors after discussion in the committee.
The Company established its Compliance Department as the organizational unit to integrate and manage Group compliance matters. This department is responsible for integrating compliance initiatives within the Company and domestic Group insurance companies.
Each unit in the domestic Group insurance companies that is in charge of compliance matters is responsible for the preparation and implementation of policies, internal rules, and measures related to compliance and for planning and operating activities related to business operating rules pertaining to insurance solicitation and sales. These units are also the focal points for fact finding and confirmation as well as conducting investigations related to activities where there are concerns about violations of internal rules and other compliance issues.
We and MS&AD insurance companies, as a part of the compliance implementation plan, resolve the Compliance Program at the Board Meetings and pursue the specific issues. The implementation and issues of the Program and responding issues are regularly submitted to each company's Compliance Committee and/or the Board Meetings.
We and MS&AD insurance companies have each Compliance Manual that states their compliance-related policies and regulations, with examples and interpretations, for board members and employees. The Manual is distributed to board members and employees, and its content is familiarized through training and examinations. Procedures for reporting inappropriate behavior is stipulated in the Manual for the speedy handling of misconduct.
Based on the Compliance Program, we and MS&AD insurance companies organize annual education / training programs for employees and agencies to raise the knowledge of laws and company internal rules and to enhance the knowledge of compliance.
MS&AD insurance companies conduct compliance-related inspections for prevention and early detection of unlawful acts that may violate laws or company internal rules.
Monitoring Group Companies
The Compliance Department monitors and reports on compliance-related activities of MS&AD insurance companies. Group Compliance Division Meetings are held to share knowledge and know-how on compliance-related issues in order to reinforce compliance throughout the group.
Speak-up system (Whistleblowing system)
The MS&AD Insurance Group has established the Speak-up system（whistleblowing systems）. Group company employees can contact the speak-up desk to make a report if a compliance-related issue arises. A contact desk has also been established at an external legal office to make it easier for whistleblowers to speak up a case. The identity of whistleblowers is protected and their information is handled carefully to protect them and ensure that they do not suffer any unfair treatment.
Anti-Money Laundering and Countering the Financing of Terrorism
The MS&AD Insurance Group has formulated a “Policy on the Anti-Money Laundering and the Countering Financing of Terrorism” and is promoting initiatives to prevent the products and services of Group companies from being used in money laundering or the financing of terrorism.
Moreover, measures to prevent money laundering and the financing of terrorism are implemented at overseas entities of the MS&AD Insurance Group, where “Guidelines on Measures for Anti-Money Laundering and Counter Financing of Terrorism” are stipulated in the “Compliance Manuals for International Operations”.
Prevention of Corruption and Bribery
The MS&AD Insurance Group has formulated a “Policy on Fair Operating Practices” and implements fair operating practices (“prevention of Corruption including bribery” and “compliance with laws and regulations regarding political activities and political funds”).
Actually at the overseas entities of the MS&AD Insurance Group, “Guidelines on Anti-Bribery Measures” are also stipulated in the “Compliance Manuals for International Operations” and the establishment of adequate rules and training is implemented.
Compliance Promotion Structure in International Business Operations
Management and staff of the overseas offices of the MS&AD Insurance Group give highest priority to compliance and take care to respect the cultures, customs, and histories of countries and regions where they serve as well as act in a manner that contributes to development of those regions. The Company has established its International Supervisory Department to integrate and manage matters related to compliance at overseas offices of Group companies, and it monitors the compliance-related initiatives of these overseas offices, while also providing guidance and assistance. This department works with the Compliance Department, which is in charge of overall integration of Group companies, to provide periodic reports regarding the status of compliance overseas directly to the Company's Board of Directors, etc. The department also engages in activities to improve and expand the overseas compliance promotion structure.
Tax compliance efforts
Recently, corporate social responsibility has increased the importance of securing tax transparency. At the same time, developments in the shifting international tax landscape have changed the wider tax environment.
MS&AD Insurance Group has been making appropriate tax payments, however, in order to make clear that all employees share the same values regarding tax and carry out appropriate tax processes, MS&AD Insurance Group has established “MS&AD Insurance Group Tax Policy” on April 2018.
Pursuant to the “Basic policies” (please see below), MS&AD Insurance Group will promote a greater awareness of taxes when performing corporate activities and retain the confidence of all stakeholders through appropriate tax payments.
- MS&AD Group values the trust and confidence of its stakeholders and is committed to managing tax matters with integrity and responsibility while recognizing the importance and social significance of appropriate tax payments.
- MS&AD Group, in performing our business operations, complies with all applicable tax laws and the relevant regulations of each jurisdiction in which it operates.
- MS&AD Group is committed to both optimizing tax-related costs as well as making appropriate tax filings and tax payments.
- MS&AD Group does not conduct any transactions only intended to avoid tax without business purposes in a way contrary to the national and local tax laws.
- MS&AD Group develops and maintains trusting relationships with the tax authorities in each jurisdiction in which it operates through sincere and transparent behavior in a timely and appropriately cooperative manner.