Outline of Policy for the Management of Conflict of Interest

Dai-ichi Life Group has a group policy for managing conflicts of interest that stipulates the core requirements for dealing with such conflicts in the group (covering Dai-ichi Life Insurance Company and all of its subsidiaries and other affiliates). The group has appropriate practices for managing transactions where there is a potential conflict of interest to ensure that gains to customers are not misappropriated due to such conflicts arising out of transactions conducted by financial institutions and other entities that are part of the group.

1. Managing conflicts of interest

Dai-ichi Life uses the following practices to manage conflicts of interest:

• (1)
  Supervision unit
  Dai-ichi Life has a supervision unit for managing conflicts of interest in the group that monitors this management and reports to the board of directors and other related bodies.
• (2)
  Company rules
  The company has the necessary rules in place to manage conflicts of interest in the group.
• (3)
  Promulgation of policy to group companies
  In addition to promulgating this policy to companies subject for managing conflicts of interest, Dai-ichi Life directs and assists the companies to establish their own policies in accordance with the nature of their operations, as listed in the attached table. Dai-ichi Life also verifies whether these policies are implemented appropriately through such activities as the collection and management of information and the monitoring of group companies, and takes action when necessary.

2. Companies subject for managing conflicts of interest

Group companies falling under the below mentioned criteria needs to be appropriately managed as companies subject for managing conflicts of interest.
Companies that are insurance companies and subsidiary financial institutions, etc. as stipulated by the Insurance Business Law, and which have certain possibility that the companies’ business may unfairly harm the insurance-related customer's interests.

3. Types of transactions subject to conflict of interest management

The management of conflicts of interest applies to those transactions where the customer has a reasonable expectation that their interests will take precedence and where there is a potential for customer gains to be misappropriated by the companies subject for managing conflicts of interest. The types of group transaction where there is a potential conflict of interest are listed below.

• (1)
  When there is a potential for customer gains to be misappropriated due to precedence being given to gains to the companies subject for managing conflicts of interest
• (2)
  When there is a potential for customer gains to be misappropriated due to inappropriate precedence being given to gains to other customers
• (3)
  When there is a potential for the group to gain through the misuse of customer transaction information by the companies subject for managing conflicts of interest
• (4)
  Other cases where there is a potential for customer gains to be misappropriated

4. How to manage such transactions

The following methods are used to manage conflicts of interest at Dai-ichi Life. This is not an exhaustive list and other methods may be used where appropriate to the circumstances.

• (1)
  Preventing any exchange of information about such transactions between companies or departments
• (2)
  Changes to the conditions or methods used to make such transactions subject to verifying their fairness
• (3)
  Preventing the execution of such transactions
• (4)
  Informing the customer of cases when there is a potential for gains to be misappropriated in such transactions

Tables

• The Dai-ichi Life Insurance Company, Limited
• The Dai-ichi Frontier Life Insurance Co., Ltd.
• The Neo First Life Insurance Company, Limited
• ipet Insurance Co., Ltd.