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AXIS Capital Holdings Limited Code of Business Conductible OF CONTENTS I. Purpose ...........................................................................................................................

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How to fill out code of business conduct

01

Start by providing an introduction to the code of business conduct, including its purpose and the values it embodies.

02

Include a section on ethical principles, outlining the standard of behavior expected from employees.

03

Detail the company's policies on conflicts of interest, bribery, and corruption.

04

Explain the procedures for reporting unethical behavior and the protections provided to whistleblowers.

05

Address the importance of confidentiality and the protection of sensitive company information.

06

Provide guidance on fair competition, antitrust laws, and the company's commitment to compliance.

07

Include guidelines for appropriate use of company resources, such as computers, internet, and email.

08

Outline the company's stance on diversity and inclusion, non-discrimination, and harassment prevention.

09

Specify the consequences of violating the code of business conduct, including disciplinary actions.

10

Finally, encourage employees to familiarize themselves with the code and seek clarification when needed.

Who needs code of business conduct?

01

Every company, regardless of size or industry, can benefit from having a code of business conduct.

02

It provides a set of guidelines and standards for employees to follow, ensuring ethical behavior and legal compliance.

03

A code of business conduct is especially crucial for companies operating in highly regulated industries or those that deal with sensitive customer or financial data.

04

It helps establish a culture of integrity, accountability, and trust within the organization.

05

Additionally, stakeholders such as investors, customers, and business partners often expect companies to have a code of conduct in place as a demonstration of their commitment to ethical business practices.

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