Compliance Basic Policy

We position compliance as one of the most important issues in group management, and all board members and employees of the MS&AD Group are committed to always recognizing the company's social responsibility and establishing a framework for practicing compliance. We have established the "MS&AD Insurance Group Compliance Basic Policy," which serves as the group's basic policy and compliance standards. Our company and group companies work positively to develop thorough compliance.

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 centrally supervise Group compliance matters. In addition, we have established the International Supervisory Department as a division responsible for supervising the promotion of overseas compliance efforts based on the "MS&AD Insurance Group Compliance Basic Policy" for our group's overseas entities. We are working to enhance and strengthen our overseas compliance efforts in collaboration with the Compliance Department.
Each group 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.
In case of any misconduct or violation committed by board members and employees, the Company implements disciplinary actions in accordance with the employment regulations. Disciplinary may be disclosed internally as a means of raising awareness and caution. Furthermore, depending on the nature and severity of the violation, it may have an impact on the compensation of board members and employees.

Activities

Compliance Program

We and group companies, as a part of the compliance implementation plan, develop the Compliance Program 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.

Compliance Manual

We and group companies have each Compliance Manual that states their compliance-related policies and regulations, with examples and interpretations, for board members and employees. The manual content is familiarized through training and examinations. Procedures for reporting inappropriate behavior is stipulated in the Manual for the speedy handling of misconduct.

Compliance-related Training

Based on the Compliance Program, we and group 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.

Compliance-related Inspection

Group 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 group 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.
The International Supervisory Department monitors the progress of compliance initiatives at overseas entities, provides guidance and support, and regularly reports on the status of overseas compliance to the Board of Directors, etc. 
We also engage in discussions with relevant departments to work towards the establishment and enhancement of overseas compliance measures.

Speak-up system (Whistleblowing system)

The MS&AD Insurance Group has established the Speak-up system(whistleblowing systems). Group company employees, etc. 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.
We have also established a global contact point for officers and employees working overseas. It is available in 15 languages and can be reported directly to our Group Head Office in Japan via a dedicated website or e-mail.

Anti-Money Laundering, Countering the Financing of Terrorism and Countering the Proliferation Financing (AML/CFT/CPF)

The MS&AD Insurance Group has formulated a “Policy on AML/CFT/CPF” and is promoting initiatives to prevent the products and services of Group companies from being used in money laundering, terrorist financing or proliferation financing.
Moreover, measures to prevent money laundering, terrorist financing or proliferation financing are implemented at overseas entities of the MS&AD Insurance Group, where “Measures for Anti-Money Laundering and Counter Financing of Terrorism” are stipulated in the “Compliance Manual 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”).
 As for the international operation of MS&AD Insurance Group, “counter measures of Anti-Bribery” are stipulated in the “Compliance Manuals for International Operations” and the establishment of adequate rules and training has been implemented properly.