1. Scope and Purpose

Aioi Nissay Dowa Insurance Company Australia Pty Ltd (Adica)1 is a wholly owned subsidiary of Aioi Nissay Dowa Insurance Co., Ltd (Aioi Japan) and both companies are part of the MS & AD Insurance Group. Adica is a locally incorporated general insurance company, authorised to carry on general insurance business within Australia pursuant to the Insurance Act 1973.

Aioi Nissay Dowa Insurance Co., Ltd (Aioi Australia Branch) is also a general insurance company established by Aioi Japan and licensed under the Insurance Act 1973 to carry on insurance business in Australia and is regulated for that purpose by APRA. Aioi Australia Branch has in place a Management Agreement with Adica pursuant to which Adica acts as the managing agent of Aioi Australia Branch. For the purposes of this policy, all references to Adica include Aioi Australia Branch unless otherwise indicated. Aioi Australia Branch has a Japanese representative on the Board of Adica being the Senior Officer Outside Australia who is included in any references to the Board of Directors or Directors.

The Board of Adica and the Board sub-committees are the senior advisory bodies of Adica. The Board, in recognising the expectations of Adica’s stakeholders, employees, customers, regulators and the community, are committed to best practice in corporate governance and compliance commensurate to the size, business mix and complexity of Adica.

Adica is committed to full compliance with all applicable laws, regulations, standards, codes and other licensing or contractual obligations to which it is bound. This Human Rights Policy sets out our social responsibility and legal obligations of Adica and its employees (as well as suppliers, vendors and contractors of Adica) under national legislation and the International Bill of Human Rights.

2. Our Commitment

2.1 Introduction

Our Human Rights Policy is designed to promote a work environment that upholds and respects the fundamental principles of human rights. It outlines the responsibilities of us as an organisation in respect of both community and social responsibility as well as its employees in ensuring compliance with human rights laws and fostering a diverse, inclusive, and discrimination-free workplace. The following legislation is relevant to this policy and any discrimination in the workplace may be considered unlawful under these Acts:

• Sex Discrimination Act 1984 (Cth)
• Racial Discrimination Act 1975 (Cth)
• Disability Discrimination Act 1992 (Cth)
• Age Discrimination Act 2004 (Cth)
• Modern Slavery Act 2018
• Australian Human Rights Commission Act 1986 (Cth).

Furthermore, Adica respects international norms in relation to human rights such as the International Bill of Human Rights and the principles defined in the International Labour Organisation Declaration on the Fundamental Principles and Rights at work.

2.2 Policy Statement

2.2.1 Equal Employment Opportunity: Adica is committed to providing equal employment opportunities to all individuals regardless of their race, colour, religion, sex, sexual orientation, gender identity, national origin, age, disability, genetic information, or any other protected characteristic under applicable Australian and/or international laws and regulations.

2.2.2 Non-Discrimination and Anti-Harassment: Adica strictly prohibits discrimination, harassment, or any form of disrespectful or offensive behaviour based on protected characteristics. This includes, but is not limited to, recruitment, internal promotions, compensation, training, and conclusion of employment.

2.2.3 Accommodation of Disabilities: Adica will provide reasonable accommodations to individuals with disabilities, as required by applicable laws, to enable them to perform their job duties effectively, unless doing so would impose an undue hardship on the specific team or company more broadly.

2.2.4 Freedom of Association: Adica respects employees' rights to freely associate, join, or not join any labour organization or employee group without fear of retaliation or discrimination. Adica does however encourage employees to be mindful of public posts., e.g., on LinkedIn and other social media where they are linked to Adica and relate to political or contentious topics/views.

2.2.5 Prevention of Forced Labour and Human Trafficking: Adica prohibits any form of forced labour or human trafficking in all aspects of its operations and expects its employees, contractors, and suppliers to adhere to the same principles. All suppliers and vendors with whom Adica engages are asked to provide (if required by law) their Modern Slavery statement as part of our procurement and risk assessment process.

3. Responsibilities

3.1 Management Responsibility: Senior management is responsible for fostering a culture that promotes human rights, ensuring compliance with applicable Australian and/or international laws and regulations, and addressing any reported violations promptly and appropriately.

3.2 HR Department Responsibility: The Human Resources department is responsible for implementing and enforcing this policy, providing guidance and training to employees, investigating complaints, and taking appropriate corrective actions.

3.3 Employee Responsibility: All employees are expected to contribute to our culture and adhere to this policy, treat all colleagues and partners with respect, and report any suspected violations to their supervisors or the HR department.

3.4 Business Processes: Across our business operations generally, including our insurance underwriting and investment decision making process, we consider social, environmental and governance aspects to ensure that we meet our responsibility to respect human rights.

3.5 As outlined in our Privacy Policy, we respect, value and acknowledge the importance of protecting our customers’ personal information to ensure that there is no adverse impact on human rights, including privacy.

4. Recruitment & Hiring Practices

4.1 Equal Opportunity in Recruitment: Adica will recruit, select, and promote employees based on merit, qualifications, and job-related criteria, without regard to protected characteristics.

4.2 Job Advertisements and Descriptions: Job advertisements and descriptions will be free from language or requirements that could discriminate against protected groups. All job ads contain the following statement: “We are passionate about building and maintaining a diverse and inclusive workforce. Adica is an Equal Opportunity Employer, and we encourage applicants from all cultural backgrounds to apply, and we will provide a safe and supportive workplace for people with disabilities”.

4.3 Selection Process: Adica will ensure that its selection process is fair, unbiased, and based on valid and relevant criteria, giving all qualified applicants an equal opportunity to compete for job openings.

5. Training & Education

5.1 Awareness Training: Adica provides regular training and educational programs to employees to raise awareness of human rights principles, non-discrimination, anti- harassment, and diversity and inclusion in the workplace.

5.2 Managerial Training: Managers and supervisors receive additional training on their roles and responsibilities in promoting a respectful and inclusive work environment, handling complaints, and addressing employee concerns.

6. Complaints and Reporting Mechanisms

6.1 Reporting Procedure

Adica has clear procedures for employees to report any concerns, complaints, or incidents of human rights violations, including options for anonymous reporting.

It is important that employees do not ignore circumstances where they are being discriminated against or victimised. Ignoring the behaviour could be wrongly interpreted as approval by the person perpetrating such behaviour(s).

Below are steps that can be taken to address individual concerns and who to contact:

• If you can, try to resolve the problem yourself with the person(s) involved as soon as possible.
• If you’re unsure of how to handle the problem yourself, or you just want to talk about the problem with someone and get more information about what you can do, talk to your manager.
• If you wish to make a formal complaint, please discuss this with your Manager or a member of the Human Resources team.

If you do make a complaint, you are responsible for ensuring that you:

• make the complaint honestly and in good faith;
• provide all the facts relevant to the complaint; and
• co-operate with the investigation and resolution processes.

Adica may not assist you to deal with a complaint where:

• the complaint has been satisfactorily dealt with or resolved previously (unless another incident has occurred since);
• the complaint is made anonymously without sufficient detail being provided so as to allow investigation or resolution of the matter;
• the complaint is frivolous, vexatious or malicious, for example where false or misleading information is provided, relevant information is withheld, facts are distorted or there is no demonstrated commitment to resolution. (Note:

Depending on the

• circumstances, these types of complaints could lead to disciplinary action including dismissal action being taken against the person making the complaint); or
• the complaint does not constitute bullying/discrimination/harassment/sexual harassment/victimisation as defined by the Policy.

If you observe an incident in which another employee is subject to behaviour which you believe to be discriminative in nature or a violation of human rights, bring it to the attention of your manager or a member of the Human Resources team.

If a complaint has been made about you, you are responsible for ensuring that you:

• cooperate with the investigation and resolution processes;
• provide a written or verbal response to the complaint which has been made; and
• provide all relevant facts to the person conducting the investigation.

Confidentiality

Anyone involved in a complaint regarding any human rights violation, or its investigation, must ensure that the circumstances and facts of the complaint are disclosed only to those people who are directly involved in progressing its investigation and resolution, or have a ‘need to know’. In particular, it is important that staff who either make a complaint, or may be witnesses to the circumstances giving rise to the complaint, do not discuss the matter outside the investigation and resolution processes.

7. Investigation

7.1 Prompt Investigation: Adica will promptly and thoroughly investigate all reported complaints or incidents of human rights violations in a fair and impartial manner.

The Chief People Officer or their designate will determine who is the appropriate person to investigate the complaint

The investigator must be someone who is impartial, and who has been trained to conduct investigations. This person may need to be sourced from outside the organisation.

The investigator must speak to the parties involved, and any relevant witnesses. The investigator must report on whether or not the complaint has been substantiated and the proposed action to be taken in response.

The investigator must document all findings and outcomes and keep detailed notes of conversations including messages left.

Keep the complainant, and the person against whom allegations were made, informed of progress. This should be done in the form of written memos.

Mediation may be a consideration in resolving the complaint. This form of dispute resolution is appropriate only if both parties agree.

The appropriate action, based on the findings of the investigation, must be undertaken promptly.

Such action may include:

• An apology.
• Changes to work practices.
• Disciplinary action.
• Training.
• Notes placed on the employee’s file.

Prior to the investigation, the complainant may be asked to provide allegations in writing.

7.2 Corrective Measures: If a violation is substantiated, Adica will take appropriate corrective actions, which may include disciplinary measures, training, counselling, or any other necessary steps to prevent future violations.

An Employee Assistance Program (EAP) is available to employees and provides professional and confidential counselling service delivered by an external company, Benestar. The EAP is available to employees and their immediate family members. Information on how to use the Employee Assistance Program is included in employee starter packs. Phone: 1300 360 354 (24-hours) Website: https://benestar.com/

8. Policy Compliance and Monitoring

8.1 Compliance Review: The HR department will periodically review compliance with this policy, identify areas for improvement, and recommend appropriate actions to senior management.

8.2 Audit and Monitoring: Adica may conduct audits or surveys to monitor adherence to this policy and identify potential risks or areas of concern.

9. Policy Dissemination and Acknowledgement

9.1 Policy Distribution: The Human Resources department will ensure that this policy is communicated to all employees, including new hires, via onboarding, training and Resources.

9.2 Acknowledgment: Employees will be required to acknowledge receipt and understanding of this policy upon joining Adica and periodically thereafter.

10. Policy Violations

10.1 Violations of this policy may result in disciplinary action, up to and including termination of employment, in accordance with Adica’s disciplinary procedures and applicable Australian laws.

11. Policy Review and Updates

11.1 Policy Review: This Policy will be reviewed no less frequently than annually to ensure it continues to remain relevant and effective. This Policy may be varied or altered at Adica’s discretion.