T&D Asset Management 
Compliance Code of Conduct

With the T&D Insurance Group's "Try & Discover" motto for creating value, we aim to be a group that contributes to all people and society.
Guided by this corporate philosophy, T&D Asset Management has established T&D Asset Management 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, our company’s corporate officers and employees must conduct business fairly in accordance with T&D Asset Management Compliance Code of Conduct by correctly understanding laws, regulations and other rules pertaining to business activities and ensuring strict compliance with them.
Moreover, T&D Asset Management will endeavor to foster a corporate culture that respects the purpose and spirit of this code of conduct.

1. Rigorously Enforcing Compliance

(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.

(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.

2. Addressing Society

(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.

(3) Political Activities and Funding

We shall comply with laws and regulations and maintain an impartial stance when conducting political activities.

3. Appropriateness and Transparency in Management

(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.

4.Respect for Human Rights and Consideration for the Environment

(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.

Duties of Managers

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