About the Code of Ethics

SJNKE operates with the collaboration of employees, assigned Parent Company staff, and agency workers and contractor staff.

It is the intention of SJNKE to ensure that all dealings with its staff are in accordance with the Sompo Japan Nipponkoa group management philosophy based on the Spirit Of Fairness.

The Company encourages a free and open culture in its dealings between its officers, employees and all people with whom it engages in business and legal relations. In particular, the company recognises that effective and honest communication is essential to its success and that malpractice is taken very seriously.

SJNKE's Code of Ethics is intended to provide guidance as to core values and principles that guide our business conduct. It is intended to be indicative rather than comprehensive, as it is not possible to anticipate every situation in our business life where ethical dilemmas may arise. More specific guidance is set out in the Company's other Policies & Procedures including the Employee Handbook.

Breach of the standards of honesty, integrity and professionalism required under this Code may result in disciplinary action, dismissal and where appropriate referral to regulatory authorities or law enforcement. Where in rare circumstances strict compliance is unreasonable or would cause unreasonable hardship, the members of the Board may allow exceptions to the Code for the limited purposes of avoiding the unreasonable consequences foreseen. Such exceptions must be in writing and retained by both parties.

You should read the Code, determine how it may apply to your activities as an SJNKE employee and act accordingly. If you are uncertain about any particular requirement, please refer to your line manager for guidance.

It is furthermore SJNKE's policy to request all employees and SJNK secondees to sign an acknowledgement of their duty to comply with the law and act with honesty and integrity.

Requirements of the Code:

  1. Ensure you act legally: Ensure that your actions and those around you are within the requirements of the law, and where possible demonstrably so. If you are uncertain where an action is legal, before acting or deciding not to act, seek advice from your colleagues, your line manager and/or the Compliance Department. If necessary, they will seek legal advice.
  2. Report concerns as to compliance with this policy by others as appropriate using the following a form from Human Resources. All reports will be considered in accordance with the Spirit of Fairness and the Whistleblowing Policy where appropriate.
  3. Manage conflicts of interest honestly and transparently. Disclose appropriately to the Company any personal interests are activities which seriously conflict with you duties to the Company. Always comply with the SJNKE Conflicts of Interest Policy. If you are uncertain how to manage a potential or apparent conflict of interest, before acting or deciding not to act, seek advice from your colleagues, your line manager and/or the Compliance Department.
  4. Act with honesty and integrity, and always treat customers, suppliers, competitors and other employees fairly and ethically.
  5. Unlawful anti-competitive activities: ensure that your conduct is not inconsistent with the requirements of law in relation to anti-competitive trade practices.
  6. Respect for others in the workplace: Always treat your colleagues with the respect they deserve, and in particular observe the requirements of our Equal Opportunities policies which articulate our commitment to avoid acting with discrimination on grounds of sex, trans-gender status, sexual orientation, religion or belief, marital status, civil partnership status, race, ethnic origin, colour, nationality, national origins, disability or age. Furthermore, always avoid conduct which may be construed as harassment.
  7. Health & Safety: Always bear in mind and obey our Health & Safety Policies and do whatever you can to safeguard the physical and mental health of others and yourself in the workplace.
  8. Proper Use of Company Assets: During the course of your employment, you may have access to or be entrusted with custody of a wide variety of assets, including for example office equipment, supplies, documents, mail, computer and IT systems, communications equipment, and data. Always treat such assets properly, and in particular preserve the confidentiality of personal and commercial data, in accordance with our Data Protection and IT Security Policies.

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