Code of Conduct
The Life Insurance Association of Japan

Life insurance business is a highly public business closely related to the stability andimprovement of people's life as well as the economic developments and has a social
mission to contribute to the enhancement of public and social welfare through its activities.
The Life Insurance Association of Japan (LIAJ) shall lay down the code of conductconsisting of the "Principles of Conduct" and the "Action Guidelines" with an aim to establish
a high reliability of life insures as the trust from customers and society obtained through thesound business operation is fundamental to comply with the mandate of customers while
also fulfilling expectations of society as well as social responsibilities.
Each life insurer and its employees shall comply with the code of conduct and its
executives themselves should take initiatives fully enforcing corporate ethics and toencourage all of its employees to comply with the code.

I. Principles of Conduct
The LIAJ shall lay down the principles and criteria which should be complied with byeach life insurer and its employees as they operate a company and conduct business asfollows:

1. Customer-oriented action
2. Action based on compliance and high business ethics
3. Action based on social responsibilities

II. Action Guidelines
According to the "Principles of Conduct" stated above, the LIAJ shall lay down the"Action Guidelines" as follows:1.

Encouraging appropriate response to customers throughout the stages fromproposal and provision of products to claims payment
To establish customer's satisfaction and trust, life insurers shall provide quality
products which meet customer's needs, render services from the customer's point ofview, and award appropriate insurance payouts.

(1) Life insurers should adequately recognize customer's needs and strive to develop and1

provide high quality products which can surely deliver the "sense of security" tocustomers.
(2) Life insurers should develop and publish a solicitation policy as well as taking measures
to ensure an appropriate solicitation. Also, life insurers should make an appropriate andsufficient explanation to enable customers to accurately understand details of products
in order to select the best product.
(3) Life insurers should provide information related to contract details and each procedure
to customers throughout the stages from the conclusion of a contract to claims andpayment of insurance money and benefits on a timely basis and in a comprehensible
manner.
(4) Life insurers should recognize that the payment of insurance money and benefits is themost important and fundamental function in the life insurance business and provide theservice in a quick, accurate, fair and careful manner. Life insurers should make asufficient explanation in order to gain understanding and satisfaction of customers
where they cannot pay out the benefits.
(5) Life insurers should cultivate their employees who can render appropriate services fromthe customer's point of view throughout the stages from provision of contracts to claims
payment.

2.

Promoting mutual understanding with customers and societyLife insures shall provide customers and society with information related to businessactivities in an accurate and proactive manner, listen extensively to customer input,
respond to it sincerely, and reflect it in the management.

(1) Life insurers should provide customers and society with information related to financial
conditions and business activities such as listening extensively to customer input in an
accurate and proactive manner in order to enable customers to accurately understandthe life insurance business.
(2) Life insurers should listen extensively to customer input and respond to the opinions andrequests sincerely in order to improve their operations, products and services.

3.

Handling properly and protecting thoroughly the customer information
Life insurers shall recognize the materiality (highly confidential and significantnature) of information received from customers through life insurance business andstrive to carefully handle and thoroughly protect such information.

2(1) Life insurers should recognize that they handle the important personal information
related to customer's life, corporeity and property and ensure its appropriate treatment
and protection in order to enable customers to provide the information with a sense ofsecurity.
(2) Life insurers should also recognize the importance of information of legal entities andorganizations obtained through each transaction and ensure its appropriate treatment
and protection.
(3) Life insurers should appropriately treat the personal information based on the PersonalInformation Protection Law, the guidelines set by the Financial Service Agency (FSA)
and the LIAJ as well as laws and provisions including guidelines.

4.

Promoting compliance
In order to establish the firm trust of customers and society, life insurers shallconduct fair business activities in conformity with the norms of society, including all
relevant laws and regulations.

(1) Life insures should comply with relevant laws for the protection of life insurance
policyholders and consumers as well as social norms in order to conduct fair businessactivities.
(2) Life insurers should comply with the Anti-Monopoly Act and compete fairly and freely inorder to promote the protection of customer's benefits and sound market development.
(3) In international business activities, life insurers should comply with international rules
and laws as well as respecting a local culture. Also, they should pay attention to any of
its impacts on a local society and economy.

5.

Blocking off the relationship with anti-social forcesLife insurers shall completely block off the relationship with any anti-social forcesthat could jeopardize public order and safety.

(1) In order to block off the relationship with anti-social forces, life insurers should takeappropriate measures as an organization, for example, resolutely refusing unreasonable
demands from anti-social forces with the cooperation of external professionalorganization.
(2) In order to prevent terrorism financing and money laundering, life insurers should takeappropriate actions to confirm identification of customers and report suspiciousactivities.
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6.

Engaging in safe and profitable asset management with due consideration for itssocial nature
Life insurers shall engage in asset management seeking to ensure safety andprofitability, taking into consideration its social and public nature.

(1) Life insurers should engage in asset management seeking to ensure safety andprofitability in order to comply with the mandate of customers.
(2) Given the public nature of life insurance business, life insurers should engage in asset
management with due consideration for its social public nature.
(3) As a major participant in both financial and capital markets at home and abroad, lifeinsurers should engage in asset management taking its impacts on each market andeconomy into consideration.

7.

Promoting efforts to address environmental issues
Life Insurers shall address environmental issues voluntarily and proactively basedon the recognition that addressing the issues are important tasks to be undertakencommonly by all humankind.

(1) Life insures should address environmental issues voluntarily and proactively bypromoting savings of energy and resources in business activities.
(2) Life insurers should enhance employee's awareness of environmental issues throughenvironmental education and support them to participate in environmental conservation
activities.

8.

Promoting social service activities
To achieve a sound and sustainable development of society which serves as thebasic infrastructure of life insurance business activities, life insurers shall actively takepart in social service activities or programs as a good corporate citizen.

(1) Life insurers should become aware that they are a member of a local community andactively take part in social service activities or programs as a good corporate citizen toachieve a sound and sustainable development of society in order to create a society thatis rich and filled with a sense of security.
(2) Life insures should contribute to resolution of social issues cooperating with non-profit
organizations, non-governmental organizations and local communities as well as
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participating to social service activities as the industry and business community.

9.

Respecting the human rights of employees and achieving a vigorous work
environment
While respecting the human rights of employees, life insures shall ensure an
employee-friendly work environment which allows each person to exercise his/her fullabilities.

(1) Life insures should ensure a fair work environment where there is no discrimination orharassment while respecting the human rights and privacy of employees.
(2) Life insurers should ensure a vigorous work environment which allows each employee
to exercise his/her full abilities, while enhancing abilities of each person through careerformation and competence development.
(3) Given the acceleration of the aging population, life insures should achieve a vigorous
work environment by supporting employees who give birth to a child, raise children or
care for aging parents and promoting their flexible working style.
(4) Life insurers should promote employment which helps to pursue social participation ofdiverse human resources.

10. Strengthening risk management measurers
Life insurers shall strengthen risk management measures under the leadership ofexecutives with appropriate operation and continuous improvement to be able to meet
obligations to customers and establish trustworthiness.

(1) Life insurers should establish the risk management system in order to recognize andevaluate various risks, and deal with them appropriately under the leadership ofexecutives with an aim to fulfill obligations to customers, then they should reexamine it
to verify if the system functions properly and implement continuous improvement.
(2) Life insures should strengthen risk management measures responding to each risk suchas insurance underwriting risks, asset management risks, operational risks and systemrisks.
(3) Life insurers should establish the risk management system responding to crisis
management and large-scale disasters for any situations that the normal risk
management system is not enough and prepare a system of appropriate payouts ofbenefits through smooth transaction of business.

511. More effective prevention of recurrence of mismanagement and fulfillment ofaccountability
In the cases of the events that shall affect customers or society, under a solid
leadership of executives, life insurers shall strive to thoroughly determine the causes,
prevent a recurrence and fulfill their accountability vis-a-vis customers and society.

(1) Life insurers should establish a company structure to promptly and appropriately
respond to a situation that affects customers or a society, for example by amending amanual.
(2) Life insurers should conduct the fact-finding research and investigate the cause of any
situation that affect customers or a society under the leadership of executives. Also, theyshould deal with it promptly and appropriately as well as putting out efforts to prevent
recurrence to restore confidence in a company. In addition, they should fulfill
accountability giving a clear and quick explanation to the customers and the society.

Adopted on June 21, 1991
Revised on October 17, 1997
Revised on June 15, 2007
Revised on June 17, 20116