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.
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