Integrity First:The Chubb Code of Conduct

INTEGRITY is at the heart of all we do, individually, and collectively as an organization. It helps to define our actions, and in turn, our reputation. For Chubb, our reputation stands for honesty, fairness and ethical behavior—and every one of us owns a piece of that reputation every time we make a business decision.

— Evan Greenbergi

Colleagues:

Chubb is more than a collection of individuals or business units. We are a community defined by our common values, and we will never allow our commercial pursuits to overshadow our dedication to those values. Our five core values are:

INTEGRITY We comply with all applicable laws, regulations and company policies—in our words and in our deeds. Honesty, character and ethical behavior guide us to do the right thing.

CLIENT FOCUS We are committed to our clients. We strive to understand their risks, we make promises and we keep them.

RESPECT We value our employees, partners and communities. We are dedicated to fair treatment, diversity, trust and mutual respect.

EXCELLENCE We recognize and reward excellence in the workplace. Performing at the highest level requires us to think and act like owners.

TEAMWORK We believe an environment of open communication and collaboration produces the best results. We encourage full participation, different perspectives, constructive criticism and a sense of pride in who we are and what we do.

Our values are the foundation upon which our business is built. Our customers, shareholders, co-workers and the communities in which we do business expect honest and ethical conduct from us each and every day. Integrity First: The Chubb Code of Conduct reaffirms our shared commitment to ethical behavior throughout the Chubb organization.

Every one of us at Chubb has an obligation to contribute to Chubb’s reputation for high ethical conduct. Integrity First will guide you in your day-to-day activities as a Chubb employee by clearly defining expectations for behavior. Your acting in a way consistent with these guidelines will strengthen our company as we face the unique challenges of the 21st century.

Please take the time to read Integrity First completely and, should you have any questions, please feel free to call the Chubb Ethics Helpline or our Chief Compliance Officer.

Evan Greenberg

Chairman & Chief Executive OfficerChubb Limited

A Letter from Evan Greenberg

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Table of ContentsA Letter from Evan Greenberg ii

Table of Contents iv

Introduction 1 Chubb’s Reputation Is the Sum of Our Individual Actions 1 The Code Applies to Everyone 1 Commitment to Non-Retaliation 2 Raising Questions and Concerns 3

Our Dedication to Each Other 4Promoting Diversity and Equal Employment 4Harassment in the Workplace 5Maintaining a Safe and Healthy Workplace 6Protecting Personal Employee Information 7Further Expectations for Managers 7

Our Dedication to the Company 8 Conflicts of Interest 8

Avoiding Bribery and Corruption 10Business Gifts and Entertainment 12Protecting Company Assets 14

Responsibilities to Shareholders 17 Financial Reporting and Accounting 17

Preventing and Reporting Fraud 18Handling Inside Information 19Money Laundering 20Trade and Economic Sanctions 22

Our Dedication to Customers and Business Partners 23Dealing Fairly With Customers, Suppliers and Competitors 23Competing Fairly 24Protecting Third Party Information 26Commercial Relationships With Governments and Entities 26

Commitment to Chubb’s Communities 27 Political and Charitable Activities 27

External Communications 28Environmental Responsibility 30

Waivers 30

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Introduction

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Chubb’s Reputation Is the Sum of Our Individual ActionsOur actions and decisions show our stakeholders what kind of company we are. We take pride in Chubb’s outstanding reputation, and we strive to live up to that reputation every day. Each of us has a part to play in Chubb’s continuing success.

Whether we are collaborating with colleagues at Chubb or working with our suppliers, vendors or business partners, we maintain others’ trust in us by working with all of our Core Values in mind. Together, these values inform the actions we choose and the decisions we make.

From time to time, however, we find ourselves in complex situations where the right thing to do is not clear. This Code of Conduct helps us make sound decisions so that we can make sure to always put Integrity First.

The Code Applies to EveryoneAll of us at Chubb are responsible for following the Code, and associated policies and procedures regardless of our position or seniority. As employees, officers and directors alike, we are all expected to formally acknowledge acceptance of this Code—that we know and understand the standards that are expected of us. We also expect anyone acting on our company’s behalf to share our values and follow the principles set out in our Code. This includes our consultants, agents and third party representatives as well as our suppliers, vendors and service providers.

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Good faith is… …coming forward with all the information you have about a situation that you believe violates our Code, a Chubb policy or the law.

…being motivated by a genuine concern or suspicion that misconduct is going on.

Making false reports and raising concerns with ulterior motives are not acceptable at Chubb.

As a good corporate citizen, Chubb—and all of us who work for Chubb—are committed to making sure our actions are within all laws that apply in our locations. Where a local law or internal standards are more stringent than this Code, we must follow the local law and standards.

Commitment to Non-RetaliationIt is important that every Chubb employee feel that he or she can freely point out conduct that may be contrary to the Code. Accordingly, Chubb is committed to protecting everyone who, in good faith, makes a report or participates in an investigation. Retaliation, harassment and reprisals of any kind will not be tolerated.

OUR VALUES IN PRACTICE:

What is a “good faith” report?Daniel suspects that there is misconduct going on in his department, but he can’t be sure. He tells his manager about his suspicions so that if there is a problem, Chubb will be able to catch it before it becomes a much bigger problem.

Amy tells her manager about a problem that she thought was a violation, but it turns out that it wasn’t a violation after all. Because Amy gave information that she honestly believed was true, she does not face discipline or retaliation.

Nathan realizes after the fact that he did something that was against company policy. He lets his manager know right away so that appropriate measures can be taken to fix his mistake.

What is not a “good faith” report?Ben and Elissa used to be a couple. After she breaks up with him, Ben, as retaliation, tells his manager that Elissa is violating part of the Code. When this accusation turns out to be untrue, Ben is disciplined for making a false report.

Frank tells his manager about a Code violation, but leaves out certain details in order to protect his friends. When the full story eventually comes to light, Frank is told that he may face discipline for hiding information that was relevant to the investigation.

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Raising Questions and ConcernsReporting concerns can help Chubb improve processes and solve problems quickly. We are encouraged to report any behavior that may be illegal or unethical. Chubb takes all good-faith reports of concerns seriously and, except where the law specifies otherwise, permits employees reporting improper behavior to remain anonymous. We understand, however, that even when we do provide our identity, our concerns and reports will be treated confidentially to the fullest extent possible, consistent with applicable law and while still allowing Chubb to conduct a thorough investigation. We also understand that an anonymous report can be more difficult to investigate. Because of this, if we ever decide to make an anonymous report, we make sure to be forthright and provide as much information as we can.

Where to go for helpYou can always bring questions and concerns to your manager or another manager you trust. Even if your manager doesn’t have all the answers, he or she will be able to escalate your report to someone who does.

Depending on the nature of the issue, you can also go to a representative of your Human Resources, Legal or Audit departments or the Compliance Officer assigned to your business.

If you are unable to resolve the issue through these channels, or if you feel uncomfortable because your concern is very severe or sensitive, the Chubb Ethics Helpline is also a valuable resource. The Chubb Ethics Helpline is free and confidential and is accessible 24 hours a day, 7 days a week, by telephone and online. For more information about how to report a serious or sensitive concern using the Chubb Ethics Helpline, go to The Village.

You can always find contact details for the Compliance Officer assigned to your business on The Village.

What happens after a report is madeChubb ensures that all investigations are conducted promptly and that they comply with applicable laws. When an investigation is completed, Chubb takes appropriate corrective or disciplinary action, up to and including termination. While you may be informed when an investigation has come to a conclusion, it is not always appropriate for the details or results of an investigation to be shared.

For more information, see The Village for more information on the

internal policies and procedures that supplement

this Code.

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Our Dedication To Each Other

Promoting Diversity and Equal EmploymentEveryone deserves to be treated with respect and dignity, and each of us plays an important role in creating a supportive, accepting and rewarding work environment. Our values form the foundation for our commitment to fair treatment, which is supported by the policies and practices outlined here.

We are committed to providing an environment in which diversity is valued. Diversity in our workforce is a key business asset, in part because it enables us to attract and retain talented individuals who contribute to our success.

In order to safeguard this asset, and in accordance with various laws and regulations, Chubb prohibits discrimination on the basis of race, color, religion, age, gender, gender presentation, sexual orientation, national origin, disability, veteran status, marital status or any other characteristic protected by law. We make all employment decisions and set all terms and conditions of employment without regard to these characteristics.

Chubb is also committed to complying with equal employment opportunity laws and/or other applicable civil rights, human rights and labor laws.

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Harassment in the WorkplaceNo Chubb employee should be subject to harassment or any other intimidating behaviors. Harassment can include any conduct that has the purpose or effect of unreasonably interfering with an individual’s work performance by creating a hostile, offensive or intimidating work environment. Harassment may consist of:

• Verbal harassment, such as threats or other abusive language, epithets, derogatory comments or slurs

• Harassment through visual media, such as inappropriate posters, photographs, cartoons, drawings or gestures

• Physical harassment, such as assault or other physical aggression, unwanted touching or blocking normal movement

• Sexual harassment—whether directed toward a person of the same or opposite gender including unwelcome sexual advances, requests for sexual favors and other physical, verbal or visual conduct based on gender

• Retaliation for reporting harassment or threatening to report harassment

Our harassment-free workplace policy applies both to the workplace and to settings outside the workplace.

Q: Tara is always one of the top producers in her department, but she repeatedly sees promotions going only to colleagues who are the same race as her manager. When she goes to her manager, he says that he hasn’t promoted her because he thinks people like her are good at sales but aren’t good managers. Tara thinks he is discriminating against her. What should she do?

A: Because Tara’s manager may be making employment decisions based on race, she should report his actions to her Human Resources representative or to another person listed in this Code.

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Q: Jon schedules an appointment with Alba, a new employee on his staff, to review her job duties. When Alba knocks on Jon’s door at 5 p.m. for the meeting, Jon says that he wants to have their discussion over a couple of drinks at a nearby bar. Alba says she isn’t comfortable with the idea, but Jon tells her, “That’s the way we do business here. You’ll have to learn to loosen up, or you won’t last long here.” As they proceed down the hall, he puts his arm around her shoulders. Is there anything Alba can do?

A: Absolutely. Alba should politely but firmly tell Jon that she is not comfortable with his behavior. She should report the situation to a manager or another person listed in this Code so that he or she can help to prevent it from happening again.

Jon’s words and actions constitute harassment because he suggests that Alba could lose her job if she refuses to go along with his overly familiar conduct. At Chubb, we pride ourselves on behaving professionally and always treating our colleagues with respect.

Please consult your regional Village spaces for information about local HR policies and procedures.

Maintaining a Safe and Healthy WorkplaceSubstance abuseAbuse of alcohol or drugs can be a serious problem in the workplace. It can pose a threat to our own health and safety as well as the productivity of our organization and the wellbeing of our outside stakeholders. Chubb maintains a drug-and-alcohol-free policy that extends worldwide and that applies to us, our vendors and our guests. This policy prohibits the use or possession of alcohol, illegal drugs or other controlled substances in the workplace, under any circumstances (except for prescription medication used as prescribed for medical treatment).

The exception to this rule is that Chubb management may approve the serving of alcoholic beverages at some company-sponsored events. In these cases, we follow all appropriate liquor laws, including laws regarding the legal drinking age. Because we want to maintain our own and Chubb’s reputation, we always avoid excessive drinking or intoxication at any work-related events.

ViolenceChubb does not tolerate threats, intimidation or acts of violence. If we become aware of a situation in which workplace violence has happened or has been threatened, we immediately report our concerns. If someone is in immediate danger, do not hesitate to contact local authorities first.

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Protecting Personal Employee InformationThose of us who have access to our fellow employees’ personal information as part of our work at Chubb must safeguard that information carefully. Any time we collect, store, modify, transfer or erase personal employee information, we make sure that we follow all Chubb policies and procedures as well as the privacy and data protection laws that apply to our work.

Further Expectations for ManagersHolding a management position at Chubb means accepting an additional set of responsibilities. We expect our managers to demonstrate a strong commitment to leadership and teamwork. Managers should:

• Lead by example to make sure all employees know and understand this Code, other Chubb policies and applicable laws

• Create an environment in which other employees feel comfortable asking questions and making reports

• Promptly escalate reports from employees to the appropriate people

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Our Dedication to the Company

Conflicts of InterestIn the course of our work, we may be presented with potential conflicts between our own interests and those of our employer. Because such conflicts of interest undermine Chubb’s success and reputation, we strive to avoid not only situations that give rise to actual conflicts of interest but also situations that create the appearance of a conflict of interest.

A conflict of interest occurs when our personal considerations diverge from the purpose, policies or operations of Chubb. The appearance of a conflict is what a reasonable person might view as a potential conflict.

LoyaltyEmployees, officers and directors of Chubb all owe the company our loyalty. This means we recognize that corporate opportunities belong to Chubb.

If, through our work, we become aware of opportunities that are appropriate for Chubb, we pursue those opportunities on behalf of the company, if it is interested, rather than on behalf of ourselves or others. We never use Chubb’s property, including proprietary information or our positions with the company, for personal gain, and we do not compete with Chubb.

In the event that we become aware of an actual or potential conflict, we will promptly consult the Compliance Officer assigned to our business or appropriate Chubb Legal Counsel.

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Q: Emily manages our relationship with one of Chubb’s business partners. Her cousin recently got a job in the sales division of this partner company. Emily is excited that her cousin is working for a company that she has a good relationship with, and thinks it would be fun to work directly with her cousin. Is there a conflict of interest here?

A: Yes. Although this is a good partnership right now, Emily must never favor her cousin’s company over others just because her cousin works there. In order to make sure this conflict doesn’t become a problem, Emily needs to disclose the situation to her manager and Compliance to decide if the partner relationship should be handled by someone else. This is no reflection on Emily’s character or capabilities—situations that appear to be conflicts should be avoided just as if there were an actual conflict.

Financial interest in other businessesHolding a significant financial interest in Chubb insureds, vendors, consultants or competitors can create a conflict of interest. As soon as we become aware of any actual or potential financial interest of this type, we should report it. Chubb Compliance can help us determine the appropriate course of action to eliminate or avoid such conflicts.

A conflict of interest can arise whether the financial interest is held by the employee or a close family member—including spouses or domestic partners, parents, in-laws, siblings, children, grandchildren, grandparents, uncles and aunts and nieces and nephews.

Involvement in other organizationsService as a director, officer or consultant of any company that does or may do business or competes with Chubb is a potential conflict of interest, even if the position is unpaid. We should also report these situations so that an appropriate resolution can be found.

Working with family membersA personal or family relationship between employees—especially if it is also a reporting relationship—may create an appearance of unfair favoritism in the workplace. To prevent this, Chubb may avoid placing any family member or person with whom there is a personal relationship in a position where he or she has direct authority over a friend or a family member.

A conflict of interest can also arise if a family member works for one of Chubb’s suppliers, business partners or competitors. In such cases, we should report the situation to our manager or the Compliance Officer assigned to our business. The resolution may involve transferring jobs or reporting responsibilities so that there is no appearance of bias.

OUR VALUES IN PRACTICE: Common types of conflicts

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Many actions and behaviors can create conflicts of interestOther common potential conflicts of interest include:

• Accepting business gifts—such as from brokers, insureds, customers, vendors and others who do business with our company (see “Business Gifts and Entertainment”)

• Conducting Chubb business with family or personal friends—such as awarding a Chubb contract to one’s brother-in-law

• Owning a significant interest in, or serving in a key role for, outside companies that do or seek to do business with Chubb, or that compete with Chubb for business

• Taking advantage of personal investment opportunities afforded to us by virtue of our positions with Chubb

• Making personal investments in companies that we know are candidates for acquisition or investment by Chubb

• Receiving or giving loans or guarantees of obligations to employees, officers or directors of other companies that do business with Chubb, or to their respective family members

Avoiding Bribery and CorruptionOur commitment to conduct business with integrity at all times means that we rely on the excellence of our products and services to win business. Because we value ethical, legal business practices, we never resort to bribery or other corrupt practices. Anti-bribery principles and laws apply to Chubb operations in all locales.

Legislation in many countries prohibits gifts or payments that are given in exchange for a favor, financial reward, improper official action or other benefit.

Annual reporting As employees, officers and directors of Chubb, we are all required to report any conflicts of interest (or potential conflicts of interest) as they arise and as part of the Chubb Code of Conduct Annual Affirmation Statement.

In the U.S., the Foreign Corrupt Practices Act (FCPA) criminalizes payments to foreign officials anywhere in the world if the payment is intended to influence an official decision to obtain a business benefit.

In the UK, the Bribery Act prohibits similar conduct which involves giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so. The Bribery Act applies to dealings with government officials as well as commercial organizations. It is also an offence under the Bribery Act to receive a bribe or not prevent bribery.

OUR VALUES IN PRACTICE:

Claire has hired a former government employee as an agent to help her navigate some of the intricacies of contracting with a local government body. When the agent requests a large sum of money up front, Claire asks him how he plans to spend it. He tells her to record it as a “business expense,” saying that he would use it to “speed up the process.”

Claire suspects that the agent is probably using the money to pay bribes, and she knows that she’s responsible for keeping honest and accurate records. She reports the conversation to her manager, and together they decide that it would be best for them to terminate Chubb’s contract with this agent.

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To guard against even the appearance of bribery, we must not:• Provide anything of value to a government official or to an employee of another organization where the purpose of that payment is to obtain an improper advantage. This includes payments and gifts made indirectly through a third party (such as an agent, consultant, sales representative, distributor or subcontractor).

• Make facilitation payments. These are small payments to secure the performance of routine services or actions that the company is otherwise entitled to receive, such as customs clearance, immigration and work permits.

For more information, refer to Chubb’s Avoiding Bribery and Corruption.

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Business Gifts and EntertainmentWhile conducting Chubb business we may occasionally give gifts and provide entertainment, and we may receive gifts or entertainment from others. These business courtesies can help us promote teamwork and build strong relationships, but we must also keep in mind that our actions must comply with company guidelines and all other applicable policies, laws and regulations.

While good judgment must be exercised in every situation, under no circumstances may we or our family members or any person on our behalf:

• Offer, solicit or accept bribes

• Solicit, accept or present gifts, meals, entertainment, travel or lodging as a business inducement or quid pro quo

• Attempt to inappropriately influence another person’s good business judgment, impartiality, fiduciary duties or loyalty

• Knowingly create a conflict of interest in light of customary industry practices

• Knowingly violate the specific practices of the other party or the law

We also make sure that any business courtesies we offer or accept:

• Are consistent with good business practices and local law

• Focus on general, and not specific, business matters

• Are not improper business inducements

• Would not embarrass Chubb if disclosed publicly

• Are not in poor taste or involve a venue that would reflect poorly on Chubb—meaning that there are no unsavory or sexually oriented events, or any other events that would violate the Chubb commitment to mutual respect

• Do not occur frequently enough to suggest an improper motive

Prohibited GiftsExcept when we receive prior approval from Compliance, employees, officers and directors of Chubb may not seek, accept or offer the following gifts:

• Cash or cash equivalents, such as bonuses, bank checks, traveler’s checks, money orders, investment securities, negotiable instruments or services, payment of credit card charges or the like, regardless of amount

• Any items with a value in excess of $250 (or the equivalent in local currency) in the aggregate during a calendar year given by, or to, any individual

For more information, refer to Chubb’s Business Gifts and Entertainment.

Chubb business units planning to hold or participate in such events must submit details of the event via The Village.

Q: Jim’s company is eager to extend its relationship with a particular client beyond property coverage. In a discussion with the client about a pending bid for other coverage, the client’s representative tells Jim about a major sporting event that the client is sponsoring and suggests that Jim’s bid would be looked at more favorably if his company purchased a block of tickets. What should Jim do?

A: Jim should absolutely not accept this offer. This hint constitutes an improper business inducement, so Jim should decline the opportunity to purchase tickets and report the conversation to the Compliance Officer assigned to his business immediately.

Travel and lodgingHosting and attending business conferences, presentations or recreational events for the purpose of general business discussions and brand-building is a generally accepted practice in our industry. Since travel is often involved, it is common for the host to provide lodging and/or transportation for attendees. We may offer or accept travel and lodging for such events, so long as the travel and lodging provided are reasonable under the circumstances and that the events are open to enough people from the industry that they would reasonably be considered to be widely attended.

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OUR VALUES IN PRACTICE: Meals and entertainmentAs employees, officers and directors of Chubb, we may accept or offer meals and entertainment from business associates (non-Chubb employees officers or directors) or prospective business associates as long as they accompany us. We may accept meals or tickets to sporting events, the theater and other recreational events (such as golf outings), provided that the purpose is for us to discuss business matters with non-Chubb business associates. That means that we generally do not accept invitations to such events if a non-Chubb business associate will not be present.

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Protecting Company AssetsOur commitment to teamwork means that we all help to protect our company’s assets. These materials make it possible for us to do our work and provide the services that our customers have come to expect.

Physical property, funds and facilitiesChubb’s physical property includes the equipment and supplies we use on a day-to-day basis and the funds that keep our businesses running as well as the facilities where we work.

Because theft, carelessness and waste have direct impacts on Chubb’s profitability, we protect the company’s assets, use them only for legitimate business purposes and utilize them efficiently.

Proprietary and confidential informationOne of Chubb’s most valuable assets is information. Chubb relies on each of us to protect its proprietary and confidential information.

Therefore, we must:• Maintain strict confidentiality of all confidential company information under our control

• Avoid sharing confidential information with anyone — even a co-worker — who does not need to know it

We consult with our legal counsel or Compliance Officer assigned to our business before disclosing confidential information to those outside the company, even when there is a legitimate business purpose for the disclosure.

What Is Confidential Information?

Confidential information can be any information that is not publicly available.

For example:

• Written and oral agreements between Chubb and employees, agents, strategic partners or other third parties

• Financial information about Chubb

• Information about potential acquisitions

• Information about Chubb investments or investment practices

• Producer compensation arrangements

• Personnel or employee information

• Non-public personal financial and medical information of customers, prospective customers or policyholders

• Information received from third parties under obligations of confidentiality

• Customer lists and agreements, market share data, producer agreements and other files

Records RetentionMany countries where Chubb does business have laws and regulations governing the retention and destruction of company records and information. Chubb’s responsibility to maintain such records and information may also be impacted by our contractual responsibilities to third parties. Chubb retains and destroys records according to the company’s applicable record retention policies. Chubb also abides by any “legal holds” that require the records to be maintained beyond typical retention schedules in light of current or anticipated litigation. Do not ever destroy, alter or try to conceal any documents that may be necessary for litigation or an investigation. When a hold has been released, this will be published on The Village. For more information about Chubb’s applicable record retention policies, contact the Compliance Officer or legal counsel assigned to your business.

ReportingIn certain circumstances, unauthorized disclosure, access or transfer of confidential information may result in a breach of data protection legislation or obligations to our customers or business partners. Upon becoming aware of any actual or potential information incident or data security breach, immediately report the event to a manager and the Compliance Officer assigned to your business. For more information about how to report such an event, go to The Village.

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For more information, refer to Chubb’s Information Incident Response

Plan.

Electronic communications and data securityChubb encourages use of technology resources—such as telephones, mobile devices, computers, software, internal collaboration tools and the Internet—provided such use does not involve personal gain or activities that could violate Chubb policies.

As employees, officers and directors of Chubb, we understand the value—and the cost—of the technology resources the company makes available to us. Chubb provides the resources we need to do our jobs, and we have a duty to use that infrastructure in responsible and appropriate ways.

We also share the responsibility for using these technologies to protect and secure company information. When we use electronic resources such as company laptops or desktops, we always ensure these resources are secure, and that access to the data they contain is password protected or otherwise

physically protected at all times.

We understand that all the communications data we create, send, receive and store using Chubb systems are the property of Chubb, as are certain tools that facilitate communication or aid in employee collaboration, such as computers, servers and shared drives, office productivity software, collaboration tools and email.

Any questions concerning how to handle electronic communications should be referred to a manager. Our Electronic Communications and Data Security Policy contains additional information.

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OUR VALUES IN PRACTICETo make sure our electronic messages are respectful, professional and secure, we…• Re-read before sending—and not just to catch errors, but to ensure that the message is simple, clear and direct

• Think twice about using “Reply to All”—send the message only to those who truly need it

• When forwarding email, delete attachments unless they are absolutely necessary

• Discuss sensitive topics by phone or in person, and reserve electronic correspondence for recording the final agreement about issues

• Avoid jokes and sarcasm. A sarcastic remark we would be able to make over the phone may be misinterpreted in electronic communication

• Never draw conclusions about the morality, legality, liability or coverage implications of a practice unless counsel has reviewed and approved the content

• Avoid using the Chubb email system for personal communications and remember that anything we put on Chubb systems may be subject to monitoring by the company, subject to local law.

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Responsibilities to Shareholders

Financial Reporting and AccountingChubb’s financial and accounting records must be accurate and timely. These records provide core information that is critical to effectively managing our business and fulfilling our obligations to shareholders, government bodies and the public. Chubb does not permit the integrity of its financial records or statements to be compromised in any way.

Chubb is required to comply with numerous financial reporting and accounting regulations and to have appropriate internal controls and processes to ensure that accounting and financial information is accurately compiled and reported. Chubb’s books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately reflect Chubb’s transactions and must conform to applicable legal and accounting requirements.

Depending on our position with the company, we may be called upon by regulators to provide information necessary to ensure that our public reports are complete, fair and understandable. We take this responsibility seriously, and we provide prompt, complete and accurate answers to inquiries related to Chubb’s public disclosure requirements.

We may not assist others in falsifying the financial or accounting records of another company. We also understand that our company’s financial information may be made available to those outside our company only with proper prior authorization, and only by those designated as official spokespeople for Chubb.

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Any questions or concerns about the integrity of Chubb’s financial records should be referred to the company’s Chief Financial Officer, Chief Accounting Officer, Chief Auditor, General Counsel or Chief Compliance Officer; the Chairman of the Audit Committee of the Chubb Limited Board of Directors (via chmnaudit@chubb.com); or any director who serves on the Audit Committee of the Board. Notification may also be made via the Chubb Ethics Helpline. The Audit Committee, subject to duties arising under applicable law, will treat such submissions as confidential.

Preventing and Reporting FraudAny deception undertaken to achieve unfair or unlawful gain for oneself or one’s company is unacceptable. We understand how dishonesty can hurt Chubb’s reputation.

Our reputations and the reputation of Chubb are critically important to our continued success. For that reason, we do not commit any acts of fraud.

Fraudulent activity can include any situation involving actions that are dishonest or contrary to the dictates of law or regulation. Many instances of fraud are addressed in other sections of this Code, including money laundering and anti-competitive behavior. It is crucial for the reputation and integrity of ourselves and our company that we report any fraudulent activity to the appropriate representatives as listed in “Raising Questions and Concerns.”

Those who do engage in fraudulent activity will be subject to strict disciplinary action, including dismissal and possible civil and/or criminal action, which could result in jail terms, severe fines and/or civil penalties.

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Handling Inside InformationMany countries where Chubb does business have securities laws that regulate the purchase and sale of securities in the interests of protecting the investing public. These laws are based in part on the belief that all persons trading in a company’s securities should have equal access to all “material” information about that company—that is, any information that a reasonable investor would consider important in deciding whether to buy, sell or hold a security.

Because the issues surrounding insider trading are so serious, we never trade in Chubb securities while in possession of material, non-public information about Chubb. The same is true if we possess inside information about any of Chubb’s publicly traded business partners.

If you are ever in doubt over whether a piece of information is material or non-public, consult your manager or legal counsel or the Compliance Officer assigned to your business. You can also refer to our Restrictions on Insider Trading and Trading Chubb Securities for more information.

Common examples of inside information:• Changes in senior management

• Mergers and acquisitions

• Projections of future earnings or losses

• Pending or threatened litigation

Also see the “Business Gifts and Entertainment” and “Avoiding Bribery and Corruption” sections of this code.

OUR VALUES IN PRACTICE:From time to time, we may disagree with others over ambiguous rules—such as legal or accounting requirements—and how they might apply in particular circumstances. Debating those ambiguities and how to handle them will not of itself suggest any dishonest motivation. At Chubb, we are encouraged to share our professional views, and we all know that integrity must be at the heart of our actions. These situations can be distinguished from the following examples of fraud:

• Embezzling Chubb funds, including collecting premiums on behalf of Chubb but not remitting them to Chubb

• Misappropriating, misusing, destroying, removing or concealing Chubb assets, including money, tangible property, intellectual property and trade secrets

• Intentionally misrepresenting any aspect of one’s background on an employment application or other documents completed or submitted in the process of obtaining or continuing employment with Chubb

• Intentionally making entries on Chubb records, financial statements or tax documents that are not accurate or in accordance with proper accounting standards

• Intentionally making entries on insurance policy or claims documentation that are not accurate or in accordance with proper industry standards

• Unauthorized handling or reporting of insurance claims

• Unauthorized use of customer information for personal gain

• Altering or falsifying business documents

• Making false statements to insurance regulators or their agents

• Offering bribes or kickbacks to, or accepting bribes or kickbacks from, government officials, vendors, contractors or agents

For more information, refer to Chubb’s Restrictions on Insider Trading and Trading Chubb Securities for more information.

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Money LaunderingWe are committed to building an environment that does not tolerate “money laundering.” In order to assist law-enforcement authorities in their efforts to apprehend criminals, to comply with local laws and to protect Chubb’s reputation, we have an obligation to watch for the signs of money laundering, to report suspicious activity and to foil those who would use Chubb for these purposes.

What Is Money Laundering?Money laundering is the process by which individuals try to make large amounts of “dirty” money—money obtained from illegal activities such as drug trafficking—seem to have originated from a legitimate source. Criminals try to move money into the mainstream quickly, which makes it more difficult for authorities to identify, and they are constantly seeking new ways to disguise illicitly obtained cash as legitimate.

Q: Robert has a customer who only last month bought an expensive insurance policy to cover a valuable private art collection—and now the customer is making a claim against the policy, claiming that several priceless pieces of art have been stolen. Robert remembers that one of his colleagues had a similar case involving the same customer about six months ago, which makes him suspicious. What should he do?

A: Robert should immediately report this case to his manager, who can escalate it to the Internal Audit or Compliance department. The fact that a customer is making a large claim so soon after purchasing the policy—and the fact that it is not an isolated incident—suggests that this customer could be attempting to use Chubb to launder money. In order to promote and protect our reputation for integrity, we should all keep an eye out for possible money laundering schemes.

Knowing Our CustomersKnowing our clients and understanding their businesses is critical to identifying and preventing money laundering schemes. Although it is more likely that attempts at money laundering will come from new customers, it’s also possible that we may see suspicious activity from established customers as they change their routines. We can look for red flags by asking ourselves:

• Is the size of the transaction consistent with the normal activities of the customer or type of customer?• Is the transaction rational in the context of the customer’s business or personal activities?• Has the pattern of transactions changed?• For international transactions, does the customer have an obvious reason for conducting business with the other country involved?

Failing to recognize and report suspicions of money laundering activities may violate local laws and damage Chubb’s reputation, so we can do our part to report suspicious transactions by:

• Immediately reporting our suspicions to our AML officer or the Compliance Officer assigned to our business• Immediately bringing the matter to the attention of a manager• Escalating concerns to the Internal Audit or Compliance department• Reporting the matter in accordance with the “Raising Questions and Concerns”

We would use the same procedures if there were ever a suspicion that Chubb employees are engaging in conduct that furthers money laundering. If suspicions involve managers, contact the Compliance Officer assigned to your business or Internal Audit or the Chubb Ethics Helpline.

OUR VALUES IN PRACTICE:

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Trade and Economic SanctionsAs a global company, Chubb must comply with a wide variety of international trade restrictions including import and export laws and trade sanctions.

In addition, we all must follow all applicable laws and regulations pertaining to economic sanctions in all countries in which we have operations.

Many of the countries where Chubb operates impose legal restrictions against doing business with certain governments and individuals. Some of these restrictions even apply to Chubb’s operations outside of the country in which the law or regulation arises. Chubb adheres strictly to these restrictions in our business dealings, both because of our commitment to comply with all laws and regulations that govern our operations and because of our desire to protect Chubb’s reputation.

Our commitments and legal requirements in this area can be complex, so we should each make sure that we understand the laws and regulations that apply to our work and our location.

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For more information, refer to Chubb’s Restrictions on Trading with Certain Countries and Individuals for more information and consult the Compliance Officer assigned to your business with any questions.

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Our Dedication to Customers and Business Partners

Dealing Fairly With Customers, Suppliers and CompetitorsWe deal honestly and fairly with each other and with our company’s customers, suppliers and competitors. We are committed to fulfilling all contractual obligations, and we take pride in ensuring that our products and services always meet our high standards for quality.

Using good judgment helps avoid actions that could be seen as taking unfair advantage of others in any way. We strive to work as a team with customers and suppliers, so we never want to be manipulative, conceal important information, use privileged information for our own advantage or misrepresent facts to others.

Dealing fairly with others also means ensuring that we are above reproach in our relationships with suppliers (see “Gifts and Entertainment”), our competitors (see “Competing Fairly”) and with government officials (see “Avoiding Bribery and Corruption” and “Commercial Relationships with Governments and Entities”).

For more information about the consumer business compliance

standards that help us make sure our customers

are treated fairly, please see The Village.

OUR VALUES IN PRACTICE: Treating customers fairly means:

• Fair treatment of our customers is central to everything we do.

• We are focused on delivering the right outcomes for our customers.

• Our customers can have confidence that we will deliver on our promises.

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Competing FairlyFair competition ensures that our customers get the best possible service at the best possible price. Competition legislation (also known as antitrust law) is designed to promote competition that is vigorous and free from collusion, and is the law of the land in most of the jurisdictions in which Chubb operates.

Competition laws are very complex, and recognizing improper actions often depends on a thorough understanding of the market in which a product is being sold, among other factors. For this reason, we consult with Chubb Legal Counsel whenever there are concerns about potential violations of competition laws or Chubb policy. Those of us working in underwriting, sales and management—and those of us who participate in trade associations, industry standard-setting groups or other meetings involving competitors—must be especially diligent about the requirements of competition laws and regulations.

OUR VALUES IN PRACTICE: Guarding against unlawful conduct

• Don’t gather information such as pricing information or underwriting criteria from our competitors or their representatives

• Avoid any agreement, understanding or discussion with any competitor concerning: • Prices or discounts • Terms or conditions of sale, including credit • Profits, profit margins or costs • Bids or intent to bid • Sales territories or marketing efforts • Selection, classification, rejection or termination of customers or classes of customers • Exchange of competitive information (such as pricing matrices, rating methodologies, actuarial forecasting or reserving practices) • Agents’ or brokers’ commissions

• Even an informal verbal agreement can violate competition laws.

• Conversations can be challenged. It is always best not to talk about price and terms and conditions with competitors.

• The law prohibits agreements, so even if an agreement is not carried out, the incident may still be a violation of these laws.

• While parallel business conduct is not unlawful, it may be seen as evidence of an agreement.

Meetings involving competitorsWhen preparing for and attending any meeting involving competitors, we must:

• Review the agenda in advance of every meeting with a sensitivity toward topics with anti-competitive implications such as “marketing practices” or “pricing”

• Encourage the organization to undertake only the business on the agenda, and to avoid discussions of sensitive topics not on the agenda

• Review the minutes after the meeting to ensure that they accurately report the actions taken at the meeting

• Consider anti-competitive risks in attending informal meetings at or around the time of the regular meeting

• Limit, as a general rule, discussions to insurance industry matters, and avoid discussing company-specific matters

Note: Chubb’s Business Practice Guidelines (“BPG”) provide additional guidance on what we can and cannot do when dealing with brokers, other intermediaries and our competitors. The BPG and other relevant policies, such as our Antitrust Compliance Guidelines, are available on The Village.

Q: Chubb has decided to join a strategic partnership with several other insurance providers in order to advance our interests. Danielle, Sam and a few of their colleagues are representing Chubb at a meeting of this partnership. Danielle notices that, over drinks one evening, Sam is being very chatty with some representatives of other companies. Danielle overhears Sam talking about an upcoming bid, which seems to pique the interest of the competing company’s representatives. What should Danielle do?

A: Danielle should interrupt the conversation immediately to prevent Sam from divulging any more details. Although the other company is now a partner, the discussion taking place is anticompetitive in nature, and could result in serious consequences for Sam and our company. Similarly, if Danielle overhears the conversation and does nothing to stop it, she could find herself in trouble as well. After Danielle intervenes and makes clear that Chubb will not take part in any antitrust activities, she should report what she’s heard to the legal counsel or Compliance Officer assigned to her business immediately.

OUR VALUES IN PRACTICE:

• General industry trends and challenges • Legislative, regulatory or judicial action that affects us all

• Industry items in the news

• Confidential information • Chubb business plans• Prices, commissions, costs or terms

• Allocation of customers or territories

DO

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DON’T

At a meeting with competitor colleagues, what can we discuss?

Q: Allen, a Chubb underwriter, has a friend, Mike, who works for the incumbent carrier on a program Allen is hoping to quote. Mike calls Allen to suggest having lunch together since they haven’t seen each other recently. Allen wants to

accept, but he also knows that there could be a business conflict of interest. What should Allen do?

A: Allen can have lunch with his friend, but he should keep the conversation to personal topics. Under no circumstance should Allen and Mike discuss any subject relating to pricing and the details of any specific account. If Mike brings up one of these topics, Allen should stop him, reminding him that it’s not an appropriate topic of conversation, then report the incident to Chubb’s Legal Department at once.

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Gathering competitive informationUnderstanding what our competitors are doing can be useful for developing our own business plans. It is perfectly acceptable for us to gather information about our competitors using any means available to the general public. For example, we can use documents such as press releases and public reports or filings. However, we must never gather this information using fraud, deception, misrepresentation or any other illegal or unethical means. Furthermore, Chubb employees who previously worked for our competitors are never pressured to disclose their former company’s confidential information, nor does Chubb otherwise knowingly receive such information from them.

OUR VALUES IN PRACTICE:Don’t participate.If you are at a meeting where sensitive competitive issues are being discussed, ask the group to stop discussing those matters. If the discussion continues, leave the meeting after requesting that your objection to the discussion and your departure are noted in the meeting records.

Protecting Third Party InformationChubb personnel always protect any information obtained from suppliers or other business partners. We treat their proprietary information with the same care we take with Chubb’s information.

Commercial Relationships With Governments and EntitiesFrom time to time, Chubb may do work for a government or one of its entities. When the government or one of its entities is our client, special laws and rules apply. These rules can be much stricter than those that govern our commercial contracts (see for example, “Avoiding Bribery and Corruption”).

When we are working on a government contract, whether individually or in a team, we understand that we are responsible for knowing and complying with the exact requirements of the contract at all times. We must never deviate from contract specifications without authorization, such as by failing to follow applicable procedures.

When working with government contracts or subcontracts, it is critical that we familiarize ourselves with and follow all of the policies, laws and regulations that apply to our work.

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Commitment to Chubb’s Communities

Political and Charitable ActivitiesWhile Chubb encourages us to be involved in our communities, we understand that our participation is a personal commitment. Except where a Chubb-organized charitable venture is involved, when we pursue political or charitable causes we do so on our own time and using our own personal resources.

Additionally, operating with or participating in political or economic boycotts is illegal in some countries and may be subject to civil and criminal penalties so consult with Chubb’s Legal or Government Affairs departments prior to participating in or supporting any boycott.

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• We don’t contribute company funds, property or services to any political candidate, party or committee without the prior approval of Chubb’s Government Affairs department.

• When taking part in political activities or speaking out on public issues, we’re careful not to create the impression that we are speaking or acting on Chubb’s behalf, unless we are authorized in advance by Chubb’s Legal or Government Affairs departments.

• We comply with all national, state and local laws regulating participation in political affairs—including those regulating contributions to political parties, national political committees and individual candidates.

• We know we may not contact, and may not authorize anyone else to contact, government personnel on behalf of Chubb for the purpose of influencing legislation or regulations without the express, prior approval of Chubb’s Legal of Government Affairs departments.

When in doubt, consult Legal, the Compliance Officer or the Government Affairs representative assigned to your business.

External CommunicationsThe importance of accuracy and transparencyWhenever we interact or communicate with anyone outside Chubb, we have an obligation to be truthful. This includes our customers, regulators, government agencies and all other external contacts. Accordingly, we must:

• Make clear, accurate statements and never attempt to misrepresent, mislead or misinform

• Cooperate fully and promptly with any internal or external investigation of Chubb business activities (in accordance with legal advice from the Chubb Legal department)

• Respond promptly, accurately and fully to requests from governmental agencies for information or documents relating to Chubb business activities. If you do receive such requests, immediately report them to Chubb’s Legal and Compliance departments. Representatives of these departments will determine the appropriate response and give the necessary authorization before documentation is provided to outside parties.

OUR VALUES IN PRACTICE: Admitting mistakes is the next best thing to not making them in the first place.The cover-up is often worse than the deed. We have all seen recent examples of this: Government officials and leaders of publicly held companies who try (and fail) to cover up mistakes and are eventually punished. Sometimes the punishment is not for the infraction itself, which may even be relatively minor, but rather for the cover-up.

It is entirely possible that, while operating in good faith in accordance with our current understanding of existing laws and regulations, we can inadvertently do something in the name of the company that will later be interpreted as inappropriate. More harm will be done to Chubb’s reputation if we try to mislead investigators or cover up what we’ve done than if we present the facts fully and honestly, as soon as we are approached with questions. Call your General Counsel or Legal department representative for additional guidance if you are contacted by a government official conducting any kind of investigation.

For more information, refer to Chubb’s Avoiding Bribery and Corruption.

Commitment to Chubb’s Communities

OUR VALUES IN PRACTICE

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Internet postings, chat rooms and blogsIn today’s electronic age, posting information on social media sites, communicating in chat rooms and blogging is equivalent to speaking to the media. We may not use these forums to discuss matters or opinions related to Chubb or any of its businesses, to disclose Chubb confidential or proprietary information or to respond to comments about the company. When we see postings that may be of concern, we must bring them to the attention of the Legal, Compliance or Communications department representatives assigned to our business.

Similar care must be taken when discussing matters with colleagues internally on The Village. We are responsible for the content we publish. We should be respectful of others at all times and take care with confidential and sensitive information about others, including customers, business matters and our fellow employees.

For more information, refer to Chubb’s Social Networking Guidelines.

For more information, refer to Chubb’s Communications Policy on Public Statements, which includes specific guidelines for different situations, as well as a list of contacts for Global and Regional Communications and Investor Relations representatives.

Public statementsBecause Chubb’s reputation is so valuable, we may not represent Chubb to the public or make public statements without the express consent and support from Chubb’s Communications department representatives.

The responsibility for managing all of Chubb’s public statements belongs to the members of Chubb’s Global Communications department, their colleagues in regional and country Communications departments around the company, the Investor Relations department and the Government Affairs department. In limited circumstances, other select individuals may also be authorized to make public statements on behalf of Chubb. This includes all written and oral comments given to the media, analysts, government officials, shareholders or audiences at conferences and seminars, or posted on the Internet.

The leaders of our business units are responsible for working with the Communications department to review opportunities for publicity, assess their risks and approve public statements.

Even when we are permitted to make public statements on behalf of our company, do not:

• Speculate on changes or provide projections on Chubb’s stock price, future revenue, earnings or financial position

• Comment on rumors about a merger, acquisition, management changes or other significant business event

• Disclose proprietary information about new products, policies or strategies

• Speculate about general market or economic conditions

• Discuss or reference specific competitors

• Cite or reference any financial information that has not been publicly disclosed

Environmental ResponsibilityChubb strives to make our workplaces environmentally sustainable. We work to be as efficient in our use of natural resources as possible, and we are committed to complying or exceeding all environmental laws, rules and regulations that apply to our work

WaiversIn a few rare situations, there may be a need to request a waiver of some aspects of this Code. If the waiver involves an executive officer, financial executive or director, only the Board of Directors or a designated committee of independent directors may grant this exception. These waivers and the reasons for granting them must be disclosed on a timely basis as required by law.

If you have ideas for improvements in this area, you are invited to bring your suggestions to chubbgreen@chubb.com.

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Chubb Executive Offices

Bärengasse 328001 ZurichSwitzerlandT: +41 0 43 456 7600

17 Woodbourne AvenueHamilton HM08BermudaT: +1 441 295 5200

1133 Avenue of the AmericasNew York, NY 10036USAT: +1 212 827 4400

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100 Leadenhall StreetLondon, EC3A 3BPUnited KingdomT: +44 0 20 7173 7000

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