Yes. With NAVEX, our third party helpline vendor, you have the ability to file a report via either the telephone or the Internet.

When you observe some behavior you believe violates our Code of Conduct, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances we have partnered with NAVEX. We would rather you report anonymously (where permitted by local laws) than keep the information to yourself.

We all have the right to work in a positive environment. With that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire company.

We certainly do. In fact, we need you to report. You know what is going on in our company - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

You should raise a question whenever you think something is not right. For example, speak up when:

• You believe there may be ethical or legal issues that conflict with our values.
• You believe there are business, operational, financial or other issues of which management is unaware.
• If you believe that ethics and compliance issues are not being resolved, either through the existing managerial chain of command or other reporting options.
• If you'd like confidential assistance on ethics and compliance issues.
• If you wish to remain anonymous when filing a report.
• If you don't feel comfortable reporting through normal channels.

The laws in some European Union countries restrict the types of reports that can be reported to the Helpline to matters related to accounting, financial audit and the fight against bribery and matters affecting the vital interests of the company or its employees' physical or mental integrity.

The phone lines are answered in a call center by a third party vendor that Chubb has contracted with. The call center operators have been trained specifically to handle these types of calls and concerns.

The Helpline is not designed for real time advice. If you make a report, a representative from Compliance or Human Resources will respond to your inquiry as quickly as possible. If you are looking for real time advice, we suggest you ask a manager, Human resources representative, or the Compliance Officer assigned to your business.

The details of your report are sent to Global Compliance and an extended team responsible for review. This extended team may include representatives of Human Resources, Internal Audit and others depending on the nature of your report.

Chubb is committed to protecting everyone who makes a report or participates in an investigation in good faith. Retaliation, harassment, and reprisals of any kind are not tolerated at Chubb.

It may not always be possible to share the results of a report due to confidentiality requirements but Global Compliance will make every effort to let you know that your concern has been resolved.

No. No identifying information is collected about the calls or reports received by the call center. Calls & internet reports cannot be tracked or traced in any way.

You may choose to remain anonymous (except where the law provides otherwise).

Your identity will be treated in the strictest confidence and will be used only to assist Chubb in investigating your concerns quickly and efficiently.

There is a section in the report where you may identify yourself, if you wish.

Our company chooses to promote ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. One only has to consider what happened in recent corporate scandals to see the disastrous effects a seemingly harmless lapse in ethics can have on an otherwise healthy company. If you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

File a report. NAVEX can help you prepare and file your report so it can be properly understood. We would rather you report a situation that turns out to be harmless than let possibly unethical behavior go unchecked because you were unsure.

When you file a report, either using the Internet or through NAVEX’s Call Center, you receive a unique report key and are asked to select a password. With the report key and your password, you can return to the NAVEX system again, either by Internet or telephone, and access the original report. At that point, you can add more details.

NAVEX provides functionality that enables company representatives to post questions for you, even if you report anonymously. When you receive your report key, you will be provided with the amount of time we expect for the report to be processed. When that time has passed, we strongly suggest you check to see if any questions have been posted. Providing the opportunity for such dialogue means situations may not only be identified but can also be resolved, no matter how complex.

The Chubb EU Ethics Helpline can be used to report suspected breaches of the Chubb Group code of conduct and/or other concerns. This might include:

• Matters relating to serious risks to the company in the fields of accounting, financial audit and the fight against bribery. For example:
  • accounting and account auditing disorders
  • false entries
  • tax evasion
  • fictitious personnel employment
  • bribery
  • terrorism funding
  • money laundering
• Matters affecting the vital interests of the company or its employees' physical or mental integrity. For example:
  • a threat to the safety of another employee
  • moral harassment
  • sexual harassment
  • discrimination
  • insider trading
  • conflict of interests
  • serious environmental breaches or threats to public health
  • disclosure of a professional secret
  • serious risks to the security of the company's information system
• In some countries, local laws and/or regulations are more restrictive with respect to the types of matters that can be reported or the subject of the matter. When submitting a report, local laws will be taken into account.

The Helpline is open to employees who wish to inform the company of matters in the categories set out above. It is a way of reporting genuine concerns which would not be adequately dealt with by other existing reporting channels such as line management or personnel representatives. No other types of report can be made using the Helpline.

We do not encourage employees to make reports to the EU Helpline anonymously because:

• Reporting anonymously does not stop others from guessing who raised the concern;
• It is harder to investigate the concern if we cannot ask follow-up questions;
• It is easier to organise for the person making the report to be protected against retaliation if the report is made openly; and
• Anonymity can lead people to focus on the person making the report, perhaps suspecting that he or she is raising his or her concerns maliciously.
• The employees who are entitled to have access to reports made through the EU Helpline are subjected to a reinforced duty of confidentiality and will take all the necessary steps to protect any individual who makes a report through the Helpline in good faith. Even if a report turns out to be groundless, it cannot lead to any disciplinary sanction if it is made in good faith. If a report is made maliciously, however, it may lead to disciplinary sanctions.
• In some countries, local laws and/or regulations are more restrictive and do not allow anonymous reporting. When submitting a report, local laws will be taken into account.

If a report falls outside the scope of the EU Ethics Helpline, it will promptly be deleted or archived. The person who made the report will be informed of this by the Legal Counsel and, if appropriate, advised to report the issue through another appropriate channel.

If a report falls within the scope of the EU Ethics Helpline, the matters raised in the report will be investigated and findings and any necessary supporting information will be provided within a period of two months from completion of the investigation to the appropriate individuals within Chubb. At the end of that two month period either:

• the company will decide to initiate a disciplinary or legal procedure, in which case the report and related information will be kept until the completion of that procedure;
• or
• the company will decide not to take any further action in relation to the report, in which case the report and related information will promptly be destroyed or archived.

If a report and related information are archived, this means keeping them in a separate information system with restricted access.

In compliance with applicable data protection law, reports and related information are not presently sent outside of the European Union. This may change in the future, however, if Chubb takes appropriate steps to safeguard transferred information.

If a report falls outside the scope of the EU Ethics Helpline and is promptly deleted (see above), there is no need to inform any person identified in the report that he or she has been reported.

If a report is archived, any person identified in the report will be informed so that he or she can exercise his or her rights of access and rectification of information relating to him or her in the report and the related information.

If and when a decision is taken to initiate disciplinary action or legal proceedings on the basis of a report, the documents on the basis of which this decision is taken will become accessible to the person against whom that action or those proceedings are taken, once the decision has been made. The company may, however, delay any response to a request for access to those documents to the extent strictly necessary to protect evidence collected for the purposes of the action or proceedings.

A person identified in a report to the EU Ethics Helpline cannot request the disclosure of the identity of the person who made the report, or of information relating to that person collected during the investigation of that report, on the basis of his or her right of access to his or her personal data under data protection law. The identity of the person making the report will always remain inaccessible through the exercise of the right of access, although it may be accessible in the framework of legal proceedings.

Although a person identified in a report to the EU Ethics Helpline has a right to require information about him or her to be rectified, this right is not absolute. It only arises where the information that he or she wants to have rectified is inaccurate, incomplete, ambiguous or out of date. If a person has been mistakenly identified in a report, he or she will be entitled to have his or her information deleted. This will also be the case where there is evidence that a person has been correctly identified in a report, but that the information about him or her in the report is erroneous. In those circumstances, that person will have the right to have information relating to him or her rectified.

Persons identified in reports to the EU Ethics Helpline also have a right of opposition to the processing of their information, but that right is also not absolute. It only arises in specific circumstances such as where he or she has not been appropriately informed about the system or where there is a patent lack of confidentiality. In such cases, Chubb may not continue to process the relevant information.