Compliance

The Executive Board adopted the revised Code of Conduct in November 2010 (http://www.hannover-re.com/resources/ cc/generic/codeofconduct-e.pdf). The rules defined therein reflect the high ethical and legal standards that guide our actions worldwide. Integrity in dealings with business partners, staff, shareholders and the general public constitutes the foundation of a successful enterprise. In both our strategic planning and our day-to-day business activities, we aspire to consistently apply the highest ethical and legal standards; for our actions and the way in which every single one of us presents and conducts himself or herself – whether a member of the Executive Board or a member of staff – are crucial in shaping the image of the Hannover Re Group.

Grounded on our corporate strategy and our Corporate Governance principles, our Code of Conduct enshrines on a sustainable basis the key rules governing integrity in our dealings with business partners, staff, shareholders and the general public. The Executive Board is expressly committed to observance of these rules, which are also binding upon all employees of the Hannover Re Group worldwide. They are intended to help us cope with the ethical and legal challenges that we face as part of day-to-day work. Each of us is jointly responsible for upholding the reputation of our company and Group in the eyes of the public at large, avoiding conflicts of interest and fostering trust through correct and value-based conduct.

The compliance report for the 2009 calendar year setting out the structure and diverse range of activities of Hannover Re in this regard was submitted to the Finance and Audit Committee in March 2010. After in-depth examination of topics such as directors’ dealings, ad hoc and other reporting requirements, the insider register, adherence to internal guidelines, consulting agreements, data protection, international sanctions and the Group-wide whistleblower system, the report concludes that two circumstances have been identified which point to breaches of relevant compliance standards. After detailed exploration of these incidents, the necessary safeguards were put in place to ensure that in future the Hannover Re Group will be in full compliance with the material external requirements for its business activities. Compliance with statutory provisions – not only in terms of their letter but also their spirit – is our overriding priority.