The T&D Insurance Group Compliance Code of Conduct

With our "Try & Discover" motto for creating value, we aim to be a group that contributes to all people and society. Guided by this corporate philosophy, the T&D Insurance Group has established the T&D Insurance Group Compliance Code of Conduct to conduct fair and appropriate business activities with integrity and sincerity for all stakeholders, including customers.

In the course of conducting business activities, the Group's corporate officers and employees must conduct business fairly in accordance with the T&D Insurance Group Compliance Code of Conduct by correctly understanding laws, regulations and other rules pertaining to business activities and ensuring strict compliance with them.

Moreover, the T&D Insurance Group will endeavor to foster a corporate culture that respects the purpose and spirit of this code of conduct.

1. Ensuring Compliance

   We shall adhere to not only the laws and regulations of countries around the world, but also international rules, social norms and internal rules. Moreover, we shall seek to understand the underlying spirit of those rules, and act accordingly with integrity.
   We are committed to conducting our business fairly and transparently and will not engage in any form of bribery or corrupt practices.

2. Maintaining and Promoting Fair and Free Competition

   We shall not engage in any unfair competitive practices, including conduct that would put our customers at a disadvantage through cartels or other forms of collusion with competitors in connection with the products and services we provide, and conduct that would put our business counterparts at a disadvantage using our bargaining power.

3. Prevention of Conflicts of Interests

   We shall always consider separating our professional and private lives in the course of conducting our duties. We shall not engage in conduct that promotes our own self-interest or the interests of third parties at the expense of the Company's interests.

4. Prohibition of Insider Trading

   As members of a publicly listed corporate group, we shall not use the non-public material information of the Company, or such information obtained in the course of performing our duties, for asset management purposes for the Company or privately, nor shall we use such information for private economic gain.

5. Protection of Intellectual Property Rights

   We shall respect the copyrights, patents and other intellectual property rights of third parties, and shall not infringe upon those rights in the course of our business activities.

1. Responding to Antisocial Powers

   We shall reject and stringently respond to any antisocial powers that threaten the order and safety of civil society.

2. Prevention of Corruption through Restrictions on Business Entertainment and Other Activities

   We shall work to prevent corruption in our relationships with business counterparts, civil servants and other parties by refraining from providing or receiving any business entertainment within reasonable bounds under normal social conventions, as well as refraining from giving or receiving gifts, in connection with our business activities worldwide.
   We do not offer, provide, receive, or accept money, gifts, or any other benefits for the purpose of obtaining improper advantages or exerting undue influence on decision-making.
   In our relationships with political bodies and in connection with donations, social contribution activities, and sponsorship activities, we comply with all applicable laws and regulations, maintain fair and transparent relationships, and take appropriate measures to ensure that such activities are not misconstrued as the provision of improper benefits.
   

3. Political Activities and Funding

   When engaging in political activities, political contributions, and related activities, we shall comply with all applicable laws and regulations and maintain a fair and impartial stance.
   We do not provide improper benefits or exert improper influence.

1. Appropriate Disclosure and Explanation of Information

   We shall accurately disclose and explain the details of the products and services we provide and the Group's management information to stakeholders, including customers and shareholders and other investors.

2. Appropriate Information Management

   We shall handle the information we obtain from customers, including personal information, appropriately in accordance with laws, regulations and other rules. Moreover, we shall appropriately manage information that the Group has not published. Corporate officers and employees shall not disclose this information to others even after they retire from the Company.

1. Respect for Human Rights

   We shall support the protection of internationally declared human rights and show respect for those human rights. Moreover, we shall endeavor to maintain a sound workplace environment that is free of discrimination and harassment by protecting workers by upholding legal and regulatory compliance.

2. Consideration for the Environment

   We shall consider the global environment in the course of conducting business activities.

1. Education and Training

   We recognize the importance of compliance and act with high ethical standards. We also strive to enhance our understanding of compliance through ongoing education and training.

2. Reporting

   If we become aware of any conduct that violates, or may violate, laws, regulations, or internal rules, we will promptly report it and strive for the early resolution of the issue.

3. Corrective Actions and Accountability

   In the event of any violation of laws, regulations, or other applicable requirements, we will take appropriate corrective measures to prevent recurrence, impose disciplinary actions and ensure accountability is clearly established.

4. Duties of Managers

   Recognizing their duty to implement the spirit of the T&D Insurance Group Compliance Code of Conduct, the T&D Insurance Group's managers shall endeavor to set a good example through their own conduct, and strive to make the code of conduct known throughout the Group and provide guidance to ensure Group-wide compliance.

December 27,2005
Approved by T&D Holdings Board of Directors