Code of Ethics and Conduct / November 2021 / 8 - 9 Anti-Bribery / Foreign Sanctions, Anti-Money Corrupt Practices Laundering (AML) and Anti-Terrorism Financing (ATF) See Compliance Portal: Global Sanctions and Financial Crime Policy See Compliance Portal: Conflicts and Related Person Global Sanctions and Financial Crime Policy Transactions Policy Bribery and corrupt activity of any kind are illegal It is RenaissanceRe’s policy to comply with all and violate our company’s policies. Bribes – applicable trade and/or economic sanctions, including illegal inducements – in any form are laws or regulations, including anti-money expressly forbidden by RenaissanceRe. Bribery laundering and anti-terrorism financing. laws apply to both commercial parties as well as RenaissanceRe will not knowingly enter into a government officials. Inducements which could contract of (re)insurance, extend or renew be deemed inappropriate – including gifts or coverage under an existing policy, pay a claim entertainment – should be carefully considered. under a policy, or make any investment or any Even the appearance of impropriety should be other payment or conduct any other business avoided. Various anti-corruption laws and where doing so would be a violation of applicable regulations are potentially relevant to sanctions or AML/ATF laws or regulations. RenaissanceRe and its employees and agents. If you suspect money-laundering or terrorism Resources are available to you should you have financing in any of your dealings at any time any questions, and you are encouraged to seek – even after having already dealt with the person guidance from the Global Sanctions and – or that someone may be committing us to Financial Crime Policy and associated policies business with sanctioned countries, companies and protocols and/or legal or compliance or individuals, you must report your suspicion personnel related to your office before you act. immediately to one of the individuals indicated Our expense policy and procedures contribute in the “How to Report” section on pages 20-21 to our management of bribery and corruption of this Code. Any assistance you might give to the risk. Any expenses must be accurately recorded transfer of proceeds from illegal activities or any in our books and records. failure to report any suspicious incident could Offering, promising, giving, requesting or constitute a criminal offence resulting in fines and accepting bribes and/or reporting inaccurate jail sentences to you and fines and other adverse expenses could result in criminal prosecution consequences for RenaissanceRe. and/or dismissal. This Code does not prohibit Note that it may also be a crime to ‘tip off’ any corporate or personal contributions to political person under suspicion, so do not disclose parties if they are permitted by law. Corporate your suspicion to such a person. political contributions must be pre-approved.
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