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
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