Anti-Bribery and Corruption Charter

Tokio Marine Insurans (Malaysia) Berhad (“TMIM”) & Tokio Marine Life Insurance Malaysia Berhad (“TMLM”); collectively known as Companies is fully committed to the fight against financial crime and makes every effort to remain in full compliance with all applicable financial crime compliance laws, regulations, and standards.

Commitment

The Companies are committed to ensure zero-tolerance against any forms of bribery and corruption whether committed by employees or intermediaries or by a third party acting for or on behalf of the Companies. We commit to maintain and preserve the highest standard of integrity, transparency, and accountability in our business operation in accordance with the ABC Framework and Guidelines:

A.   Top Level Commitment
B.    Risk Assessment
C.    Undertake control measures
D.    Systematic review, monitoring and enforcement
E.    Training and Communication

Policy, Procedures and Principles

We adopt an Anti-Bribery and Corruption Policy (“ABC Policy”) which sets out the principles and procedures to help prevent corruption by, on behalf of, or against the organisation, and to detect, report and deal with any breach which may occur.

Employees shall always exercise proper care and judgement, avoid conflict of interest, conscientiously maintain the highest degree of integrity and ethics, fully comply with all the applicable laws, regulatory requirements and policies/circulars issued by us.

Strict Prohibition

The Companies prohibits employees to make and accept any facilitation payment or kickbacks of any kind, whether directly or directly, in exchange for business favours, information and favourable treatment. We ensure employees shall comply with the ABC Policy.

Entertainment, Hospitality & Gift (“Benefits”)

The Companies prohibits employees from receiving, accepting or indulging lavish, extraordinary or excessive gift, entertainment and hospitality, to or from current or potential customers, vendors, agents and business partners, either directly or indirectly which may influence the employee’s judgment in a decision-making process or put the employee in a position of conflict.

Business Associates

We work with organisations and persons that conform to standards consistent with our ABC Policy.

Reporting Channel

The Companies practices an open-door policy and encourages all Employees to share concerns and suggestions with their Heads of Department (“HOD”) who can address them in an appropriate manner. All employees and business associates are encouraged to report any act of bribery and corruption directly to the following channels:

• Whistleblowing Policy

All informers are reassured that their identity would be protected in accordance with the existing law enforce and applicable in Malaysia.

Violation

We would take stern disciplinary action against employee and terminate the business transaction with the concerned business partners who is found in breach or non-compliance of the ABC Policy.