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個人情報の取扱に関する宣言

We, Swiss Re Asia Pte. Ltd., Japan Branch, in carrying out the reinsurance operations based upon the trust by customers, deeply recognize the importance of the protection of personal information, adhere to the Act on the Protection of Personal Information (the "Personal Information Protection Act"), Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (the "My Number Act") , Guidelines for Protection of Personal Information Protection in the Financial Sector and other applicable regulations and guidelines, and put appropriate treatment of personal information, individual numbers and specific personal information into practice.

1. Collection of personal information

We collect personal information through legal and fair means to the extent necessary to conduct business.

2. Purpose of use of personal information

We specify the objectives of the use of personal information as below, and utilize them within the defined scope of objectives and to the extent necessary in the conduct of business:

Underwriting, performance, maintenance and administration of reinsurance contracts;
Payment of reinsurance claims and benefits;
Invitation and provision of event and seminar and taking surveys;
Provision of information relating to our operations and enhancement of our administration, products and services;
Recruitment and management of employees and determination of working conditions;
Other operations related or incidental to reinsurance business

3. Safety management of personal information

We comply with the applicable laws and regulations and designate the person responsible for the management of personal information, and, in order to prevent a leakage, loss or damage of personal data, and to protect against undue access to personal data, we take the following safety measures, and adhere to them:

① Organizational safety management measurement

Assign a person responsible for the handling of personal data
Establish a reporting and communication system from employees to the responsible person.

② Human safety management measurement

Regularly provide employees with education and training on personal data protection.
Internal employee handbook stipulates confidentiality of personal data.

③ Physical safety management measurement

Restrictions on entry and exit, lock control, etc.
Prevention of leakage of personal data when carrying equipment, electronic media, etc. that handle personal data.

④ Technical safety management measurement

Implementation of access control
Implementation of a mechanism to protect information systems from unauthorized access or software to protect personal data from external threats.

⑤ Understanding the external environment

When handling personal data in a foreign country, regularly grasp the personal information protection system of the country and implement safety management measures.

Main foreign countries for provision of personal data: Switzerland, India, Singapore, Slovakia (EU member country)

Overview of the systems concerning protection of personal information of foreign countries: Please refer to the Personal Information Protection Commission website below:
https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku

4. Outsourcing of handling of personal data and specific personal information

When outsourcing the handling of personal data and specific personal information, we set up the criteria for selecting the outsourcee, and confirm in advance the information management system of the outsourcee, and in case of overseas outsourcee, the relevant foreign legal system, etc. We will carry out necessary and appropriate management of the outsourcee.

5. Provision of personal data to a third party

In principle, we obtain the individual’s agreement if and when providing personal data to a third party. However, it may not be the case under the following circumstances:

When required by law
When outsourcing to the extent necessary to operations
When jointly using personal data with our Group companies (please refer to item 6. "Joint use of personal data" below).

6. Joint use of personal data

We may jointly use the following personal data with our Group companies (Swiss Re Ltd, its subsidiaries and affiliates) for the purpose of use of personal information provided in item 2 above.

Items of Personal Data:	name, address, telephone number, email address, department/section, job title, gender, date of birth, insurance contract details and insurance accident details
Responsible Company:	Swiss Re Asia Pte. Ltd., Japan Branch Marunouchi Nijubashi Building 22F 3-2-3, Marunouchi, Chiyoda-ku, Tokyo 100-0005 Japan Atsuhiro Dodo, Representative in Japan

7. Handling of specific personal information

The Purpose of use of specific personal information is limited under the My Number Act, and we will not collect or use specific personal information beyond the prescribed purpose of use. Furthermore, we will not make any joint use of specific personal information, as stated in No.6 above.

8. Request for disclosure, amendment, suspension of use etc. under Privacy Protection Law

Please direct requests for any notice of matters, disclosure, amendment, or Suspension of Use of Personal Data and Specific Personal Information, etc. held by us under the Personal Information Protection Act to the address listed in No.9 below. With regard to the personal information that we received from an original insurance company, we will handle the request properly in consultation with the original insurance company for disclosure, amendment, suspension of use of the personal information of an individual if requested by the individual upon verifying the personal identity.

9. Contact for consultation on the treatment of personal information

Swiss Re Asia Pte. Ltd., Japan Branch
Marunouchi Nijubashi Building 22F
3-2-3, Marunouchi, Chiyoda-ku, Tokyo 100-0005 Japan
Tel: 03-5219-7800
Monday to Friday except for public holidays 9:00-12:00, 13:00-17:00

10. Contact for complaints regarding the treatment of personal information

We are a member of Foreign Non-Life Insurance Association of Japan, which is an authorized personal information protection organization. Complaints regarding the treatment of personal information by a member of such authorized personal information protection organization is handled by the following organization:

General Association Insurance Ombudsman, Inc.
Tel: 03-5425-7963
Monday to Friday except for public holidays 9:00-12:00, 13:00-17:00
Home Page Address: https://www.hoken-ombs.or.jp/

11. Policy concerning the protection of personal information and continuous improvement

We thoroughly educate and train employees, and continuously make a review and improvement to strengthen the protection of personal information.

Atsuhiro Dodo: Person in Charge for Management of Personal Information.

指定紛争解決機関

Designated Financial Alternative Dispute Resolution (ADR) Organization

About our designated ADR

We have the Basic Contract on Procedure and Practice with the legally authorized ADR Organization. In case a dispute with us cannot be resolved, you are entitled to make a statement to the ADR. For further details, please refer to the ADR Home Page below.

General Association Insurance Ombudsman, Inc.
Tel: 03-5425-7963
Open: from 9 a.m. to 12 noon, from 1p.m. to 5p.m.
Excluding Sat, Sun, Holidays, Year end and New Year days etc.
Home Page: https://www.hoken-ombs.or.jp/

利益相反管理方針（概要）

Introduction

Swiss Re Asia Pte. Ltd., Japan Branch ( "the Company") will properly manage and conduct business operations in order to avoid the Company’s clients from being unduly interfered with their interests when the Company performs any transaction that may cause a conflict of interest between the Company or subsidiary financial institutions of the Company (Paragraph 3, Article 100-2-2 of the Insurance Business Act) (collectively "the Group Companies") and the clients or any transaction that may cause a conflict of interest between the clients of the Group Companies.

1. Definition of Conflict of Interest

"Conflict of interest" is defined as a situation where there is a conflict of interest between a Group Company and clients and a situation where there is a conflict of interest between the clients of Group Companies.

2. Identifying Transactions That May Cause Conflicts of Interest (Subject Transactions)

The Company will identify any transaction that may give rise to an undue conflict of interest ( “the Subject Transaction”) among transactions that fall under the categories indicated below and properly manage the business operations in order not to unduly interfere with the interests of clients;

Any transaction where the interest of a client conflicts with the interest of the Group Company or that gives rise to a conflict of interest between the clients of the Group Companies;
Any transaction that a client and the Group Company compete for the same interest or clients of the Group Company compete the same interest; and
Any transaction that the Group Company gains benefits using the information obtained through relationship with a client or that other client of the Group Company gains benefits using the information obtained through relationship with a client of the Group Company.

3. Methods of Managing Conflict of Interest

The Company will manage conflict of interest by selecting and implementing one or combination of the measures described below:

Segregate the team that performs the Subject Transaction from the team that performs the transaction with the client;
Change the Subject Transaction or conditions or manners of the transaction with the client;
Terminate the Subject Transaction or any transaction with the client; or
Disclose to the client that the Subject Transaction may unduly harm the interest of the client.

4. Framework for Management of Conflict of Interest

The Company, for proper management of conflicts of interest, will identify and manage conflicts of interest in an integrated manner in compliance with current laws and regulations by appointing Compliance Officer as conflicts of interest manager that is independent of client management section.
The Company ensures employees of the Company fully aware of the Conflict of Interest Policy by providing training and education to the employees.
The Company properly retains all the records concerning identifying and managing the Subject Transactions for five years.
The Company regularly assesses the adequacy and effectiveness of the conflict of interest management system and continuously makes improvement.

5. Scope of the companies subject to conflict of interest management

All the Group Companies including the Company and Swiss Re International SE shall be subject to this Conflict of Interest management. Group Companies, which are engaged in financial business (namely financial instruments business, banking business and insurance business) in foreign countries and do not conduct any Subject Transaction, are not subject to this conflict of interest management. However, for any Group Companies which are found to potentially conduct any Subject Transaction during the periodical assessment of Japanese domestic business operation of Group Companies, such Group Companies are subject to this conflict of interest management.

反社会的勢力への対応にかかる基本方針

Swiss Re Asia Pte. Ltd., Japan Branch (hereafter, SRALJ) decides on “SRALJ Basic Policy on the Anti-Social Forces” to keep the public trust as insurer and ensure the appropriateness and soundness of business operations based on the purport of the “Guidelines to protect corporations from damage by Anti-Social Forces” (Mutual agreement by organizers meeting for Cabinet Conference on Counter-measures for Crimes dated 19 Jun 2007).

1. Measures as Organization

SRALJ shall take actions against the Anti-Social Forces by the initiative of the management as the organization not leaving it to person or section in charge. The management and administration in case of the unjust demand by the Anti-Social Force shall be taken by Compliance Officer.

2. Coordination with External Expert Functions

SRAJ shall keep close relationship with external functions including the Police, the Promotion Center for Expulsion of Forces, lawyers etc so that SRALJ can receive appropriate advice and support.

3. Cutting off the Relationship including business transactions

SRALJ shall cut off any relationship with Anti-Social Forces including business relations. SRALJ shall reject any unjust demand from Anti-Social Forces.

4. Legal actions from both Civil and Criminal in case of emergency

SRALJ shall take actions aggressively from both Civil and Criminal against any unjust demand from Anti-Social Forces

5. Prohibition of deals behind the scenes and provision of funds

SRALJ shall not make any deals with Anti-Social Forces behind the scenes or provide funds to hide the fact even in case the unjust demands are based on misconducts under the business operations

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