Code of conduct

In all aspects of our business we ensure we know the legal requirements and comply with them. Zurich has an unwavering commitment to fair and responsible business conduct.

We must adhere to all laws, rules and regulations of the countries in which Zurich operates as applicable at our workplace as well as with our internal policies. Moreover,

• We ask not only if something is legally permissible, but also if it is the right thing to do
• We conduct ourselves with honesty, fairness, dignity and integrity in our workplace and whenever we act on Zurich’s behalf
• We respect the protection of international human rights within our sphere of influence, and will make sure that we are not complicit in human rights abuses
• We acknowledge that just because others may do something, that doesn’t make it right

Zurich is further committed to forthright, full and prompt disclosure when communicating with regulators, supervisors and governments.

This means we are open, honest and cooperative with any government investigation or regulatory examination that involves Zurich.

Once a government investigation is underway, we take special care to prevent the destruction or alteration of any paper or electronic information relevant to the investigation or examination.

Zurich maintains an environment that is respectful of all employees and free from all forms of discrimination and harassment. We take pride in the diversity of our workforce as it contributes to making Zurich an employer of choice.

Zurich does not tolerate discrimination or harassment in the workplace on the basis of age, disability, ethnicity, national origin, gender, race, color, religion, marital status, sexual orientation or any other perceived differences. These principles extend to all employment decisions including recruiting, training, evaluation, promotion and reward.

Employees are expected to treat one another with respect and dignity.

Speak up if you have been a victim of or have witnessed discrimination, harassment or bullying.

Zurich recognizes the right of its employees to freedom of association and collective bargaining. All employees have the right to freely form and join groups for the promotion and protection of their employment interests.

Zurich does not tolerate any form of forced or compulsory labor, and child labor.

The above principles are in accordance with the internationally recognized core employment standards of the International Labour Organization.

Zurich endeavors to provide its employees with safe, healthy and secure work environments.

We comply with all applicable health, safety and environmental policies and requirements including:

• Keeping our working area clean, healthy and free from hazards that can lead to accidents, emergencies, health issues or security risks
• Avoiding any behavior or actions that could put you or your colleagues at risk
• Promptly addressing and reporting any safety or health concerns, risks or hazards
• Integrating environmental considerations throughout our business
• Minimizing our direct and indirect environmental impact through continuous improvement in environmental performance

Environmental protection is integral to sustainable value creation for both Zurich and society.

Protection of data and safeguarding confidential information is a priority for Zurich. We take appropriate measures against unauthorized or unlawful processing of data that Zurich maintains and against its accidental loss, destruction or damage.

As a Zurich employee you are expected to:

• Safeguard confidential information of Zurich, its employees, its customers, business affiliates and other stakeholders through its entire life cycle, from origination to safe disposal
• Collect, process and share personal data only for specified, legitimate and required purposes and to the extent necessary
• Access, use and disclose confidential information only on a need-to-know basis and when authorized for a legitimate business purpose
• Respect privacy rights and preferences of the persons whose data we process
• Consult with your local data protection officer or legal function before data is transferred across national borders (including to other Zurich entities)
• Ensure that electronic personal data or confidential information is protected in transmission and storage through adequate technical safeguards
• Report data security breaches through appropriate management channels as quickly as possible

Personal data is any data in electronic or manual files that relates to an identified or identifiable individual or legal entity, e.g., health and family matters, passport number, banking information, business plans, etc.

Confidential information means any non-public information including business methods, product plans, marketing, finance, technical data, etc.

Business, financial reporting, legal and tax considerations require that Zurich retains and maintains complete and accurate records.

It is therefore important that you:

• Accurately and completely record all business transactions
• Deal with financial data accurately, promptly and with due care while following Zurich’s accounting principles
• Retain records and data, including electronic files and emails, for as long as required by law, regulation or policy, unless Zurich advises that the purging of all or certain categories of documents has been suspended (for example because of pending litigation or imminent government investigation)
• Ensure that records and data are available and accessible to authorized persons only
• Do not alter or falsify information on any record or document
• Prevent access to data by unauthorized persons
• Do not take any action to fraudulently induce, coerce, manipulate or mislead, when interacting or communicating with customers, suppliers, government, regulators, auditors or others inside or outside Zurich

Zurich’s reputation depends on the actions and integrity of its employees. It is important that any decision taken as a Zurich employee is based on the interests of our company or shareholder, and not based on self-interest.

Every day we make business decisions and may occasionally be presented with a conflict of interest between our company’s and our personal interests, when working with customers, brokers, agents, or others.

It is imperative that you always maintain your objectivity and ensure your judgment is not compromised by personal or family interest.

Refrain from any activity if a conflict of interest arises.

Disclose conflicts of interest to your manager and ensure that they are satisfactorily managed and/or eliminated.

Get the applicable approvals from your superiors, before accepting any mandates, such as a director, officer, or significant investor/owner of a non-Zurich company or organization.

Consult with Compliance whenever in doubt.

Zurich is committed to fair and responsible business and prohibits all forms of bribery, or corruption and any business conduct that could create the appearance of improper influence.

Employees are expected to avoid any conduct that could have the appearance of improper influence and must therefore:

• Ensure that all gifts, entertainment and other advantages, either given or received, in connection with business activities are appropriate to the circumstances, and moderate in terms of value, frequency and quantity
• Never give or receive gifts, entertainment or other advantages that
  • Are cash payments or cash equivalents
  • Are intended to create the appearance of obtaining or retaining an improper business or personal benefit or undue government action
  • Could cause a conflict of interest for either party
• Ensure that political, charitable and similar contributions comply with applicable laws and the requirements of Zurich’s policy. They must not be used for any illegal or improper purpose

If, for example, you are active in trade associations or if you have a leading role in such areas as underwriting, marketing, or claims, you must be especially aware of anti-trust and fair competition regulations.

Zurich prohibits engaging in any anti-competitive practices or behaviors that are illegal or inconsistent with Zurich’s best interests.

All Zurich employees must respect Zurich’s competitors and refrain from engaging in practices or behaviors that have the purpose or effect of eliminating or lessening free and fair competition.

It is prohibited to:

• Enter into agreements, understandings or coordinated activities with actual or potential competitors; in particular, do not coordinate with competitors to:
  • Fix prices, premiums or specific elements thereof
  • Limit or restrict the kind or quantity of products or services supplied
  • Allocate markets geographically or according to trading partners, customers segments or product lines
• Abuse a dominant position in a particular market
• Enter into vertical agreements or arrangements with entities operating at different levels in the distribution chain, such as agents, distributors or suppliers that have the purpose or effect of eliminating or lessening free and fair competition, in violation of applicable laws
• Use confidential competitive information of Zurich or competitors without authorization or misuse their intellectual property

Zurich believes in the integrity and transparency of the financial markets and therefore is committed to ensuring that information learned on the job must never be used for improper personal gain

Zurich expects each employee to protect inside information they possess and not to use or misuse such information whether for their own or anyone else’s investments.

Always remember the following:

• Do not deal in Zurich securities or securities of other companies (either directly or through other persons) while in possession of inside information.
• Do not provide tips or make recommendations about any securities while in possession of inside information.
• Keep in mind that before dealing in Zurich securities, you must exercise particular care and seek all necessary approvals.
• Dealing includes any sale, purchase, or holding of, or agreement to sell, or purchase any securities or interest in such securities, including if done off-market.
• Securities include any publicly listed/traded financial instruments such as shares, ADRs, bonds, debentures or other securities or financial instruments whose price is materially depending on them, including any options and derivatives.
• Inside information means any material non-public information that could be price-sensitive, i.e. affect the price of a security.

Reputation and brand are critical Zurich assets.

Forthright and accurate communication with our stakeholders helps us to successfully manage both our reputation and brand. You should refrain from commenting on any speculations or rumors about Zurich or any of its divisions and not disparage Zurich competitors.

In general, you should direct requests for information from outside Zurich about Zurich to the appropriate function to deal with the matter according to local guidelines. Special rules apply for responding to inquiries from certain external parties.

As a Zurich employee, you must:

• Refer all requests for information from the media representatives to the local media relations office or the Group Media Relations department
• Direct all queries from investors, analysts or shareholders to the Group Investor Relations & Rating Agencies department
• Forward all inquiries from regulators to the local Legal and Compliance department or Group Regulatory Affairs department as appropriate.

Keep in mind that posting information on social media sites such as Facebook, LinkedIn etc. is speaking to external parties, hence the same rules apply.

Protection of assets and prevention of fraud and crime are key to building and maintaining the value and trust of Zurich’s stakeholders.

The misuse of Zurich’s property or the property entrusted to us would negatively impact our reputation and our interests.

You are therefore required to:

• Take precautions to safeguard and protect Zurich property
• Use Zurich property and resources only for business purposes and not for personal or professional gain or for inappropriate or unlawful purposes
• Avoid unauthorized or improper use or disclosure of a Zurich name, logo, service mark, trademark, trade secret, confidential document, patent or copyright
• Not misuse your position for fraudulent or illegal purposes
• Not misappropriate or illegally conceal, divert or obtain money, assets, data, information or services
• Not misrepresent or falsify information