Our Code of Ethics & Conduct
Code of Ethics and Conduct RenaissanceRe Holdings Ltd. Updated as of November 2021
Corporate Values (FRIPP) Our Corporate Values form the basis for how we expect to behave and are the cornerstone of both our ethics expectations and our business success. Focus: Filtering inputs to avoid distraction, in order to concentrate on tasks that lead to the accomplishment of an overall goal. Respect: Treating all of our stakeholders with a genuine sense of worth for their person. Integrity: Maintaining an approach to all dealings that is upright, honest and morally sound. Precision: Having the ability and spending the time to produce results that are accurate and thorough, tempered with practicality. Passion: Undertaking action fueled by conviction, excitement and enthusiasm.
Code of Ethics and Conduct / November 2021 / 1 Contents Message from our CEO 2 When and How to Report 18 Overview 3 When to ask for help 18 Compliance Responsibilities 3 Where to get help 18 Reporting any concerns 19 Code Principles We respect and value our clients, 4 Whistleblowing 20 partners and shareholders How to report 20 We respect and comply with 6 Whistleblowing process 20 relevant laws and regulations Contact information 21 We respect and protect RenaissanceRe 10 We respect and value each other 14 We respect and support the 16 communities in which we operate Scope Failure to follow our References in this Code of Ethics and Conduct standards of conduct (the “Code”) to “employees” include all of our Integrity and fair business practices are critical to officers, employees and, where relevant, our our reputation. Violations of this Code or relevant directors. References to the “Company” include laws by any employee may be deemed to be RenaissanceRe Holdings Ltd. and its affiliates. serious misconduct under the terms of Any questions about how any part of this Code employment and may subject the employee to or relevant policies may apply to you should be criminal, civil or regulatory sanctions, as well as addressed to your local office legal to internal disciplinary actions – up to and representative or RenaissanceRe Holdings including immediate termination of employment. Ltd.’s Group General Counsel. In appropriate cases, RenaissanceRe may also Certification refer misconduct to the proper authorities for prosecution. This may subject the individuals All employees and directors are required to involved to civil and/or criminal penalties. submit an annual certification of their Waivers understanding of and compliance with this Code and the policies relevant to them as Waivers of any element of this Code or the posted on our internal Compliance Portal. underlying policies in our Compliance Portal This certification is a compulsory component may be granted or withheld from time to time of our annual review and performance by the Company at its sole discretion. To the management program for employees. extent required by applicable laws and No Retaliation regulations, any waivers of this Code for the Certain laws and regulations prohibit retalia- benefit of directors or executive officers will be tory action against employees who report po- submitted for approval by the Board of tential wrongdoing in certain circumstances. Directors (or a committee of the Board of There are no adverse employment repercus- Directors) of RenaissanceRe Holdings Ltd., sions for those who report, in good faith or on and will be disclosed to the shareholders of a reasonable basis, potential or actual ethical RenaissanceRe Holdings Ltd. where required. and compliance violations. Retaliation is a violation of this Code and should be reported in accordance with this Code.
Message from our CEO At RenaissanceRe we believe that how This Code and our corporate values and we act is as important to our success as principles provide you with a framework what we do. We are committed to being a to guide your behavior and professional trusted partner to our stakeholders and dealings. We always expect you to are proud of the long-term relationships comply with the spirit as well as the letter we have fostered with our customers, of the various laws, policies and investors, communities and employees. procedures which govern our operations We maintain and build this trust by and activities. operating to the highest standards of It is not possible to provide an exhaustive business conduct and grounding all of list of scenarios that you may encounter. our interactions in our core values of If you have any questions or concerns, Integrity and Respect. Integrity means the end of this Code contains more “maintaining an approach to all dealings details on where to go, as well as that is upright, honest and morally sound” information on our Whistleblowing Policy while Respect means “treating all of our and Process should you need to report stakeholders with a genuine sense of any suspected violations of our Code. worth for their person.” We also Please also refer to the policies, protocols encourage honest, open exchange of and guidelines posted on our ideas, believing that diverse perspectives Compliance Portal and in local offices. and experiences make us a stronger Thank you for the work you do every day company and partner. to reinforce the trusted reputation that defines RenaissanceRe. I am proud to be part of our team. Kevin J. O’Donnell President and Chief Executive Officer
Code of Ethics and Conduct / November 2021 / 2 - 3 Overview At RenaissanceRe, we aspire to the highest They are also captured in this Code, standards of honesty, integrity and business which provides five broad principles to conduct. These standards are reflected in which we are all expected to adhere. our Corporate Values, as well as in our Mission, Vision and Purpose statements. These principles are: We respect and value our clients, partners and shareholders We respect and comply with relevant laws and regulations We respect and protect RenaissanceRe We respect and value each other We respect and support the communities in which we operate All policies referred to in this Code can be found on the internal Compliance Portal on our Company Intranet. • We are a high integrity organization and Compliance we require compliance with the spirit – Responsibilities as well as with the letter – of our policies and procedures. • The decisions we make are our own. Outside experts can help inform our good judgment, but ultimately we must take responsibility for our decisions. • Ethical, high integrity and compliant conduct is the responsibility of each of us.
We respect and value our clients, partners and shareholders Fair Dealing Relationships are a crucial RenaissanceRe serves a wide variety of clients and customers and deals with a broad range of component of the success other stakeholders and counter parties on a of any business. They are built world-wide basis. In conducting your activities, you on concern for and loyalty to our are required to comply with the conduct clients, partners, shareholders requirements for our products and appropriate and other stakeholders. business practices in those territories. You should be aware of the market and regulatory standards We believe that making ethical that might apply to you given your responsibilities and location, such as the Lloyd’s Conduct decisions, acting in the best Minimum Standards or fair dealing associated with interests of our Company, being listed on the New York Stock Exchange. You shareholders and capital are required to deal fairly with RenaissanceRe’s partners and serving them customers, suppliers, competitors and employees, faithfully will help us generate and not take unfair advantage of them through manipulation, concealment, abuse of privileged long-term value. We seek and information, misrepresentation of material facts, or provide value through our any other unfair-dealing practice. Consult your financial security, quality Supervisor or other legal or compliance resources products and responsive as appropriate. service to our clients and partners. Our corporate strategy Confidential Information reflects these objectives. (including Personally Employees should be familiar Identifiable Information) with our corporate strategy as it relates to their position, and See Compliance Portal: their conduct should reflect our Information Security Policy Information Security Principles strategy, values and principles. Confidential Client Information and Trade Secrets Policy Insider Trading Policy Confidential information takes many forms and includes information about our Company, our clients, our partners, our colleagues and potentially other stakeholders. Confidential information includes all non-public information. Disclosure or use of confidential information may provide an advantage to competitors or may harm our Company, clients or partners. Confidential information also includes personal information about our employees,
Code of Ethics and Conduct / November 2021 / 4 - 5 clients, partners or their clients or partners. If you are given access to potentially confidential or personal information, you should review the IT Security and Data Governance Policies on the Compliance Portal to ensure you are protecting our clients, partners and the Company and are complying with relevant laws and regulations. You are required to maintain the confidentiality of information entrusted to you by RenaissanceRe and persons or entities with which we do business, except when disclosure is authorized or legally mandated. Employees must not misuse confidential information for personal or other benefits that may conflict with RenaissanceRe. Unauthorized disclosure of confidential or personal information may result in legal disputes, fines and/or penalties for RenaissanceRe and where appropriate, internal disciplinary actions, up to and including termination of employment. Q: Several years ago, we signed a confidentiality agreement with a company that provided a lot of information for our internal modeling. Included in the documentation was a client listing with phone numbers. I learned recently that this information has been made public See Compliance Portal: on a website. I believe another area of Information Security Policy RenaissanceRe could benefit from the Information Security Principles information. Can I be viewed as violating the Confidential Client Information and Trade confidentiality agreement by providing Secrets Policy something that is now in the public domain? Insider Trading PolicyA: Potentially ‘Yes’, unless the confidentiality agreement specifically allows you to share the information with the other area of RenaissanceRe. Even though the information is publicly available, you may still be bound to the original terms of the contract. If you believe that something in the public domain could be of value, you should suggest that other RenaissanceRe team go to the public domain to gather the information and you should NOT use the original information in any manner other than for its original intention.
We respect and comply with relevant laws and regulations Regulatory or Compliance- Related Communications The industries in which we and Issues operate are generally robustly regulated. It is our individual See Compliance Portal: responsibility to be aware of Regulatory Interactions Protocol laws and regulations which You have a duty to report completely, apply to each of us and to accurately and truthfully in all communications comply with them, both in spirit with regulators. and in letter. As we are subject to regulation in a number of jurisdictions, you are expected to read the Regulatory Interactions Protocol and be aware of how it applies to you. In particular, and before you take any action, you should understand your authority, if any, to communicate should any oversight body or regulator contact you. You are always expected to notify RenaissanceRe Holdings Ltd.’s General Counsel or your local office legal representative as soon as you become aware of any potential or actual regulatory or compliance-related issues affecting any of the RenaissanceRe companies. Accounting and Financial Reporting See Compliance Portal: Real Time Disclosure Policy SOX and Periodic Disclosure Rules Policy Our financial reporting is required to be reliable, accurate, complete, fair, understandable and timely. No false or deliberately inaccurate entries are to be made in any books or records, and no employee is to engage in any untruthful arrangement to that effect, or to direct anyone else to make false entries. Additionally, no undisclosed side agreements, oral and/or written, which would modify the terms of an executed contract, are to be made. We have established policies, guidelines and procedures and require that you comply with these policies,
Code of Ethics and Conduct / November 2021 / 6 - 7 guidelines and procedures to ensure the employees’ interests are aligned with those of integrity of our books and records. You are also our shareholders. required to cooperate in a forthright and fully If you are found guilty of insider trading, you may candid manner when dealing with internal or be subjected to, among other things, fines and/ external auditors or accountants. or a jail sentence. Under certain circumstances, Failure to comply is a violation of laws and you can also be held responsible for securities regulatory requirements, which may result in, trading activities of anyone to whom you among other things, jail sentences and/or disclose material and non-public information. fines for individuals and may include financial Q: I want to sell shares of RenaissanceRe penalties for RenaissanceRe. If you become common stock during an open trading aware of or suspect a potential violation of window, but I am not sure if I have material, accounting policies, guidelines or procedures, non-public information regarding recent please report the potential violation through catastrophe losses. any one of the options listed on pages 20-21 What should I do? of this Code. A: If you are ever in doubt whether you have Insider Trading / Market Abuse material, non-public information you should contact your local office legal counsel or the RenaissanceRe Holdings Ltd. Group General See Compliance Portal: Counsel before you trade any securities. Insider Trading Policy Executive Investments in Insurance Sector Antitrust / Fair Competition If you are thinking about trading – either buying See Compliance Portal: or selling – our securities or those of our clients, Worldwide Antitrust Policy counter parties, brokers or partners, you are first required to familiarize yourself with our Insider We expect all employees to deal fairly when Trading Policy and you are required to make any interacting with competitors and to avoid trades in compliance with that Policy. It is against anti-competitive practices. Compliance with our policy, and may be against the law, to trade worldwide antitrust and competition laws is any securities – not just RenaissanceRe’s – if you required from all employees to foster free, fair and possess material non-public information. competitive markets for the benefit of consumers. Passing material non-public information on to Illegal agreements regarding pricing, terms, someone who may buy or sell securities customer or territorial market share or allocations (“tipping”) is also illegal. It is also against our and improper exchanges of competitively policy for any employee or director to directly sensitive information with competitors must be hedge, short-sell or pledge as collateral avoided. The term ‘competitors’ is to be interpreted RenaissanceRe securities. broadly, given the manner in which business in We have controls in place to help employees be our industry is conducted. Even informal verbal compliant with our Insider Trading Policy communications on these matters, such as at including the use of ‘trading windows’, social events or industry-attended events, could restrictions on investing in our sector and a be construed as violations of competition laws. Stock Ownership Policy to ensure senior Antitrust and competition laws are complex. You are required to read and comply at all times with our policies.
We respect and comply with relevant laws and regulations You should seek advice from your local office legal representative or RenaissanceRe Holdings Ltd.’s General Counsel if you have any questions about the policies or any specific activity being considered. Be aware that conduct does not have to be intentional to be anti-competitive and potentially violate the relevant laws. Failure to comply with competition laws can result in, among other consequences, significant fines and legal action against RenaissanceRe, reputational damage and possible criminal prosecution for those individuals involved. Q: Is it legal to talk to our competitors about pricing trends, as long as we don’t talk about specific prices of RenaissanceRe or our competitors’ products? A: While generic discussions on industry trends may not be illegal, we must be mindful of how these discussions may be perceived and how this information may be used by others. Accordingly, as a simple rule, you should always decline discussions with competitors regarding pricing and terms. Where you are unsure you should ‘ask before you act’ and obtain guidance concerning the proposed communication.
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.
We respect and protect RenaissanceRe You are obligated to act Conflicts of Interest in the best interests of See Compliance Portal: RenaissanceRe, and by doing Conflicts and Related Party so, you will be aligning your Transactions Policy actions with the best interests We respect the rights of employees to manage of our shareholders, for whom their personal affairs. We encourage involvement we strive to generate of employees in activities beneficial to the long-term value. community. However, situations may arise which may create a conflict of interest, or may appear to create a conflict of interest, between our individual interests and the best interests of RenaissanceRe and require ethical handling. Generally, you owe a primary duty to RenaissanceRe or, in some circumstances, other stakeholders, to advance its legitimate interests or corporate opportunities and to comply with other duties you may owe to RenaissanceRe. In some circumstances you may owe a duty to stakeholders other than RenaissanceRe. You should seek to identify and avoid situations in which objectivity, independence or the ability to act in the best interests of RenaissanceRe or other relevant stakeholders are compromised or could appear to be compromised. A conflict of interest occurs when an individual’s private interest interferes in any way – or even appears to interfere – with the interests of the Company as a whole. A conflict situation can arise when an employee, officer or director takes actions or has interests that may make it difficult to perform his or her work objectively and effectively. If you find yourself exposed to an actual or potential situation in which you or family members are, or could appear to be, receiving an improper benefit as a result of your position at RenaissanceRe, you are required to communicate this potential conflict of interest as soon as it is identified. Communicate such situations to one of the individuals indicated in the “How to Report” section on pages 20-21 of this Code. Actual conflicts of interest could result in a variety of legal and regulatory issues such as antitrust violations, incomplete financial disclosures, regulatory consequences or damage to our reputation .
Code of Ethics and Conduct / November 2021 / 10 - 11 Certain employees associated with • Loans RenaissanceRe Fund Management Ltd. may Loans or guarantees obtained through your have additional obligations related to identifying employment at RenaissanceRe could appear to and managing conflicts. impair your objectivity. Neither you nor your family Q: I am responsible for selecting a third-party may borrow funds or receive guarantees from any vendor to provide services to RenaissanceRe. person, business or firm who you know has My family member runs a company that I business dealings with RenaissanceRe. Nor may believe would be good fit. What should I do? you or your family seek to use the RenaissanceRe A: You can identify this company as a potential name, position in a market, or goodwill to receive vendor, but you must disclose the connection any benefit on a loan transaction, without prior to your Supervisor and local compliance written approval from RenaissanceRe Holdings representative to determine next steps. Ltd.’s General Counsel. • Gifts and Entertainment This policy does not apply to ordinary course The practice of giving and receiving appropriate personal loans such as mortgages, car loans or gifts and entertainment should compromise credit cards assuming the terms are generally neither your objectivity nor RenaissanceRe’s available to the public. reputation. You may give and receive reasonable • Outside Business Activities / Employment gifts and entertainment related to business activities. However, no gift or entertainment It is possible to create a conflict of interest due to should be offered or accepted, regardless of your outside business activities. To avoid any amount, with any indication that inappropriate potential conflict of interest, an employee requires treatment will result. approval, including prior approval in the case of new activities, from RenaissanceRe Holdings Our Conflicts and Related Party Transactions Policy Ltd.’s General Counsel before entering into any provides the specific reporting and approval outside business activities. requirements related to gifts and entertainment. If you are unsure about whether you can accept/ Examples of outside business activities are included offer a gift or entertainment, consult with your local in the Outside Business Activities section of the office legal or compliance representative. Conflicts and Related Party Transactions Policy. Q: Every year, a supplier sends me a couple of • Corporate Opportunities bottles of champagne in the festive season You are prohibited from taking for yourself personally – can I accept them? opportunities that are discovered through the use of A: Yes, but our policies do not allow giving or corporate information or position unless disclosed receiving gifts that could compromise, or in advance and approved, consistent with our appear to compromise, our ability to make Conflicts and Related Party Transactions Policy. objective and fair business decisions. Any gifts or gratuities deemed extravagant or with • Public Communications an aggregate annual value greater than $500 must be immediately reported to your See Compliance Portal: Supervisor and your local office legal or compliance representative. If you are unsure, Real Time Disclosure Policy Public Communications – Investor you should review the matter with the Meetings, Presentations and Media aforementioned persons. You may be Interactions Policy required to turn the gift over to the Company or donate it to charity. We communicate with the public in a consistent, accurate and truthful manner. As a public
We respect and protect RenaissanceRe company our external communications must be carefully managed. Only certain individuals are authorized to communicate or interact publicly on behalf of RenaissanceRe. Unless you have been specifically authorized to communicate on behalf of RenaissanceRe, then you are not permitted to do so. Public communications could relate to investor meetings, public speaking engagements or communicating with the media. If you receive a request to communicate from any of these sources, please refer to our Public Communications – Investors, Presentations and Media Policy. Adherence to this policy will ensure that our communications about RenaissanceRe are accurate, consistent, lawful and appropriately protective of proprietary or sensitive information. Corporate Veil See Compliance Portal: Corporate Veil Protocol You are expected to understand what you are authorized to do in the course of your work, what the entity you represent is permitted to do and to seek clarification from your manager if you are uncertain. You may have a role that requires you to work for more than one of the operating entities in the RenaissanceRe group. If you do, you need to understand which entities you work for, in what capacity, and act accordingly, based on the Corporate Veil Protocol. Our Corporate Veil Protocol explains how you could damage a relationship with another party by making unintended commitments or act outside permitted company activities – either of which could violate laws, regulations or internal policies, and/or expose entities within the corporate group to heightened litigation risk. Records Management See Compliance Portal: Global Record Retention Policy Document Management Procedures Recording Policy
Code of Ethics and Conduct / November 2021 / 12 - 13 Our systems and processes at RenaissanceRe RenaissanceRe. You have an obligation to protect are designed to ensure that information is it. The loss of exclusive use of our intellectual available when and where it is needed, is property could reduce our competitive maintained in an organized manner and is advantages and its misuse or theft by you could appropriately destroyed when it is appropriate to lead to termination of employment and/or legal do so. This information includes business action, including potential criminal penalties. records (paper and electronic) which are required to be maintained in a manner compliant Corporate Information Security with applicable laws and regulations. You are required to comply with RenaissanceRe’s record retention requirements and to understand your See Compliance Portal: role with respect to the issuance of any ‘Legal nformation Security Policy Hold’ instructions’ as outlined in our policies. nformation Security Principles Failure to comply can result in civil, regulatory or Autoried ser Privacy Policy Global ecord etention Policy criminal penalties against RenaissanceRe and employees involved in such violations. Our information and technology systems are critical for the efficient operation of our businesses E-Communications and are a key component of our competitive advantage. All of us are expected to understand All forms of electronic communication such as and respect their corporate importance. email or social media sent internally or externally can potentially become permanent records and could You are obligated to read and comply with our be difficult to understand or interpret over time in various Information Security-related Policies and absence of the current context. We expect our procedures and other formal instructions you employees to be mindful of the appropriate use of may receive from our IT Security or relevant RenaissanceRe approved modes of electronic personnel. You should also be aware that our communications and of our policies with respect to computer systems and the information stored or other forms of communication such as social media created on them are the sole property of tools (e.g. Facebook, LinkedIn, Twitter, Instagram, etc.) RenaissanceRe and you should have no to avoid damaging situations, personally or for expectation of privacy in your usage of them. RenaissanceRe. Generally, employees using any sort of social media should be respectful of others, Protection and Proper adhere to our confidentiality policies and clearly Use of Company Assets identify their opinions as their own and not those of RenaissanceRe. Violations of these expectations could result in internal discipline, up to and including RenaissanceRe’s property is intended to be termination of employment. used for business purposes and should be protected from theft or misuse. All employees, Intellectual Property officers and directors should protect RenaissanceRe’s assets and ensure their Our intellectual property is comprised of many efficient use. Limited personal use of such items elements, including our Company identity, is permissible when such use does not lead to internally-developed systems and models and inappropriate company expense, interfere with internal processes. All such property should be business operations, create a conflict or violate safeguarded and used for the sole benefit of this Code.
We respect and value each other We strive to provide a safe, Non-Discrimination healthy and supportive work RenaissanceRe is an equal opportunity We strive to provide a safe, employer. We provide equal opportunity to all environment that promotes the applicants and employees regardless of race, healthy and supportive work well-being of our employees and color, religion, national origin, age, sex, sexual environment that promotes orientation, gender identity, marital status, the value that they contribute to the well-being of our employees pregnancy, disability, military status or other our global organization. and the value that they legally protected categories. Discrimination contribute to our global based on the categories listed or otherwise organization. protected by law in the jurisdiction in which you are employed is prohibited. Discrimination may be direct or indirect, it may occur intentionally or unintentionally and it may take many forms including victimization, improper communications or improper actions. All work- related decisions, subject to applicable laws, must demonstrate respect and value for employees’ qualifications, merits and performance. Discriminating against an individual could result in disciplinary action, including dismissal. Harassment and Bullying See Compliance Portal: Harassment in the Workplace Policy RenaissanceRe is committed to providing a work environment that is free from bullying or harassment. Just as you are expected to deal with others in a professional and respectful manner, you are also entitled to such treatment. We require supervisors and managers to comply with the obligations and standards of the territories in which their team members reside. Violations of this policy may result in disciplinary action, up to and including termination. Reasonable work-related requests and legitimate and constructive criticism of performance or conduct do not constitute bullying or harassment. Q: I am being teased by another employee and I consider it harassment of a sexual nature. What should I do?
Code of Ethics and Conduct / November 2021 / 14 - 15 A: If you feel comfortable doing so, you may Political Contributions notify the offending individual that the and Public Office conduct is not welcome. You should report complaints to your immediate Supervisor, or For the most part, individuals are free as private to any Supervisor, senior manager or human citizens to endorse or contribute to political resources representative with whom you feel parties and candidates, contribute to ‘issue comfortable. Your communication will be advocacy’ groups, serve in political campaigns or kept confidential and/or anonymous to the run for public office. Certain employees extent possible. associated with RenaissanceRe Fund Use of Illegal Drugs and Alcohol Management Ltd. are prohibited from making certain political contributions. Affected employees RenaissanceRe is committed to providing a have been informed and you should ask if you are work environment that is free from illegal drugs unsure as to whether this prohibition applies to and inappropriate alcohol consumption. you. Corporate political contributions, however, Unlawful manufacture, distribution, must be lawful and be approved by dispensation, possession, use, sale or purchase RenaissanceRe Holdings Ltd.’s Chief Executive of illegal drugs and/or related paraphernalia is Officer or Group General Counsel or their prohibited, as is being under the influence of designees. Involvement in political campaigns or drugs. Alcohol may be available at various running for an elected position in your personal work-related events and you may, if you choose, capacity must not constitute a conflict of interest consume moderate amounts, but it is your sole with RenaissanceRe and must use neither the responsibility to ensure your conduct and RenaissanceRe name nor company resources. demeanor is professional at all times. RenaissanceRe will not pressure any ‘Professional conduct’ extends to avoiding employee to make a political contribution, nor activities where laws or regulations may be will the Company reimburse employees for breached, such as operating motorized vehicles individual contributions. when impaired. RenaissanceRe reserves the right to take appropriate steps to ensure Diversity, Equity and Inclusion compliance with this policy, including drug Our people are our most valuable resource and testing as permitted by law. we are committed to maintaining a culture that Any violation of this policy, including conviction for supports every person in doing their best work. involvement in illegal drugs, could result in We have a global, cross-functional Diversity, disciplinary action, up to and including termination. Equity and Inclusion (DEI) Council that sets and Employees are encouraged to seek assistance executes our DEI Strategy and focus areas in for themselves or their dependents for drug or partnership with Senior Management. Our alcohol problems, and to report suspected overall goal is to embed DEI principles in our abuse by co-workers. RenaissanceRe provides daily practices (“in our DNA”). By Seeking assistance and access to rehabilitative Diversity, Creating Equity and Practicing treatments and programs for employees (or their Inclusion, we will build an even stronger culture dependents) who seek it. and company. The Human Resources department and your local office Employee Handbook can provide additional guidance.
We respect and support the communities in which we operate Corporate Relationship with the Community We strive to provide a safe, RenaissanceRe operates in At RenaissanceRe, we value responsible healthy and supportive work corporate citizenship. We strive to extend our many regions and we are environment that promotes high standards of ethical conduct to the committed to interacting with the well-being of our employees communities and the environment in which we the communities in which we live, work and do business. operate in a respectful, ethical and the value that they manner and in compliance contribute to our global Employee Relationship with all applicable laws and organization. with the Community regulatory requirements. Each employee of RenaissanceRe is expected to conduct themselves appropriately in the community – consistent with our view that each of us is a company ambassador when we are representing RenaissanceRe at business functions. We are aware that, although your private life is your own, the relatively small markets in which some of our businesses operate can alter our expectation of both privacy and the attribution of an individual’s conduct to RenaissanceRe.
Code of Ethics and Conduct / November 2021 / 16 - 17 Community Support We seek to add value to our communities by encouraging individual employee donations through our corporate charity gift matching policy, supporting local charities at the corporate level and sponsorship of sporting, artistic and educational initiatives.
When and how to report When To Ask For Help Where To Get Help We do not believe it is possible to describe • This Code of Ethics and Conduct every situation in which you may be required to • Your Supervisor make a judgment about ethics and compliance violations. If you encounter such a situation, your • Your Human Resources Manager conduct can frequently be guided by the • Your Unit / Function Leader following questions: • RenaissanceRe Holdings Ltd.’s • Is your proposed action ethical and legal? General Counsel • If it were made public, such as in a • Your Local Office Legal Representative newspaper, would it damage RenaissanceRe’s • Your Local Office Compliance reputation, a colleague’s, or your own? Representative • How would you feel if your Supervisor or • The Compliance Portal co-workers or your family found out? • Our Whistleblowing Process • Would you risk your job over it? You are always encouraged to ask if you have any questions relating to proper and ethical business conduct. At RenaissanceRe, the only bad question is the unasked question.
Code of Ethics and Conduct / November 2021 / 18 - 19 Q: Do employees really get Reporting Any Concerns dismissed for violating our ethical standards? If you become aware of anything that even appears to violate A: Yes. We take our ethical any part of this Code, laws, regulations, legal obligations or our obligations seriously and policies or of inappropriate or negligent conduct or will enforce them. In some cases, concealment of any of these, you are encouraged and employees have been dismissed expected to report the possible violation promptly. for violations including but not limited to theft, fraud, conflict of interest, sexual harassment, If you report a concern, our commitment falsifying records or failing to to you will be to: cooperate in an investigation. Q: I am concerned that someone may have breached this Code, • Act promptly and appropriately in response to your concerns but I am not really sure. What should I do? A: Even in circumstances where • Maintain confidentiality to the fullest extent possible during you are unsure but have any investigation of the reported concern questions or concerns, we encourage you to report the perceived breach of this Code. • Ensure there are no negative corporate repercussions for In order to facilitate the reporting raising an item in good faith or assisting with an investigation of employee communications, we have established a Whistleblowing Policy, which provides certain mechanisms for employees to submit, on a confidential basis, communications in good faith. There are no adverse employment repercussions for any employee with respect to good faith reporting of complaints or questions.
Whistleblowing How To Report Whistleblowing Process There are a number of ways through which you can raise a concern: See Compliance Portal: Whistleblowing Policy • For issues relating to accounting, internal accounting controls and/or audit, please There are a number of avenues available to you contact RenaissanceRe Holdings Ltd.’s to report your concerns, including by submitting Group General Counsel, your local office confidential or anonymous communications legal representative, the Chief Accounting under our Whistleblowing Policy by using Officer, your Unit / Function Controller, or ComplianceLine. ComplianceLine is an the Chair of the Audit Committee. external vendor, free to you, confidential and • For discrimination, harassment or contactable 24 hours a day, via the internet or bullying issues, please follow the by phone. Communications will be kept Complaint or Grievance section of your confidential to the extent possible, including as office’s Employee Handbook. required by relevant laws, and it is our policy that there be no adverse corporate • For money laundering concerns in the repercussions to the individual who reports in United Kingdom or Ireland, please contact good faith a potential incident. the U.K. Money Laundering Reporting Officer. For all other locations, please If you are concerned because your issue contact Bermuda Compliance. relates to a person(s) identified on these pages, then please contact ComplianceLine • If you are a member of the RenaissanceRe in one of the ways outlined on the next page Holdings Ltd. Board of Directors and you and request that either the Chair of the have an ethics-related concern, please RenaissanceRe Holdings Ltd. Audit contact RenaissanceRe Holdings Ltd.‘s Committee, the Head of Internal Audit or the Chair of the Board, Chair of the Audit Chief Accounting Officer handle the report. Committee, Group General Counsel or the external counsel of the Board of Directors. • For any other issues, please speak with your Supervisor, your Human Resources department, your Unit / Function Leader, RenaissanceRe Holdings Ltd.’s Group General Counsel, your local office legal representative or compliance personnel. All of the reporting methods above involve direct communication. If you would prefer to communicate with an outside party, you may choose to use our Whistleblowing process, which is outlined as follows.
Code of Ethics and Conduct / November 2021 / 20 - 21 Q: I think that someone may have Contact Information violated our Code, but I don’t want to report it because I’m concerned Confidential External Reporting about my report not being kept private and maybe damaging my career because of who the person COMPLIANCELINE is. What should I do? A: You should contact • WEB: ComplianceLine and request that – renre.mycompliancereport.com they use the ‘Bypass Notification’ reporting process for this issue. – Our Intranet homepage This will bypass the standard – Our Compliance Portal internal management and instead will be managed by either the Audit Committee Chair, the Head • PHONE: of Internal Audit or the Chief Bermuda: +1 855 430 3624 Accounting Officer – you can Ireland: 1 800 851 759 even choose. Remember, there UK: +44 800 086 9819 are no repercussions for any US: +1 866 596 0049 employee with respect to good Singapore: +65 800 852 3831 faith reporting of complaints Switzerland: +41 80 056 26 84 or questions. Australia: +61 1 800 836 362 Q: What is a “good faith” report? A: Being motivated by a sincere Confidential Internal Reporting belief or genuine concern or suspicion that a violation of the Code or other inappropriate • PHONE: behavior may have occurred. +1 441 295 4513 Making false reports and raising To call RenaissanceRe Holdings Ltd.’s Group concerns with ulterior motives are never acceptable. Actual General Counsel proof or first-hand knowledge is (Feel free to call collect) not necessarily required, but you should provide the Company • E-MAIL: with all the information you have. [email protected] • MAIL: c/o General Counsel RenaissanceRe Holdings Ltd. Renaissance House 12 Crow Lane Pembroke HM 19 Bermuda
