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000 800 100 4382 (Tollfree 24x7) An Independent Ethics Hotline for
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LAW POLICIES

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Policy available on the Intranet.
GOVERNANCE REGULATIONS

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COMPLIANCE
#RakshakaranKiReet HANDBOOK
 Message from the Managing Director & CEO

Dear Colleagues,

As we continue to pursue our Vision - "To be the pre-eminent protection

provider - enabling dreams, inspiring healthier and happier lives", and the Mission-
"To provide the best and simplest life and health insurance solutions", each one of us
has a role to play in this journey and we must commit ourselves to re-inforce our credo -
Doing the Right Thing, in the Right Way, with the Right People and the Right Results
will come.

This handbook provides an overview of the principles of conduct for all business units
and employees, as elucidated in "Tata AIA Life Code of Conduct", in a simple and easy
to understand manner.

Note that it is the responsibility and duty of each one of us to:

Comply with all applicable laws and regulations.

Observe and promote high ethical business standards and be honest.
Respect and treat fairly; all our colleagues, consumers, suppliers, other business
partners and our stakeholders.
Be loyal to the Company and protect our assets, confidential information, data and
know-how.
Secure the health and safety of our colleagues and neighbours.
Protect the overall reputation of the Company.

It is only by observing these values and duties that we will be able to ensure the long-
term success of the Company.

Non-compliance to the Code is a violation and we will continue to take tough action
against those who do not comply.

Please join me in strengthening our great legacy and demonstrate the values we share
in everything we do.

With kind regards,

Rishi Srivastava
Managing Director & Chief Executive Officer

01 02
Key Contents

Vision, Mission and Values 04

Code of Conduct 05

Non-Discrimination & Non-Harassment 06

Conflict of Interest 07

Whistleblower Policy 08

Anti-Fraud Policy 09 Our Vision

Anti-Money Laundering Program 10 To be the pre-eminent protection provider - enabling dreams, inspiring healthier
and happier lives.
Prevention of Sexual Harassment Policy 11

Consumer Privacy and Data Security Policy 12

Our Mission
Social Media Policy 13 To provide the best and simplest life and health insurance solutions.

Gifts and Entertainment Policy 14

Anti-Trust and Fair Competition Policy 15 Our Values

Anti-Bribery and Anti-Corruption Policy 16 Consumer Obsession

Consumer is paramount in everything we do.
Political Activities 17 • Innovate solutions and services to delight our customers.
• Transparently deliver on promise.
Passion for Excellence
Set and achieve the highest standards.
• Do the Right things in the Right way.
• Take accountability and drive results.
• Pioneer Change.
People - Our Core
Inspire myself & my colleagues to be and deliver the very best.
• Create and take distinctive opportunities for development.
• Demonstrate courageous leadership at all times.
• Exceptionally reward outstanding performance and right behaviour.

03 04
 What is the Code of Conduct?

The Code of Conduct is a set of principles, standards or expected behaviour, which

every employee is required to adhere to and which guide the decisions, procedures
and systems at Tata AIA Life.
What is in it for employees?
• It is important that honesty, integrity, accountability and respect for colleagues as
well as for consumers and stakeholders, should be constantly reflected in the
behaviour of the employees at all levels across the Organisation.
• Every employee shall be responsible for adhering to the Code in his/her professional
capacity.
• These will help maintain ethical business standards and build public confidence.

What are the consequences of violation of the Code?

Failure to adhere to the Code may attract disciplinary action, including loss of
employment.
Report violations of the Code to the Management Non-Discrimination and Non-Harassment
Employees are encouraged to report violations to the Management. Details for
Whistleblowing are provided at the last page of this Handbook.
What is Non-Discrimination and Non-Harassment?
All employees have the right to work in an environment, free from harassment of
any nature. Harassment in any form, whether physical, verbal or psychological; is a
violation. Harassment is defined as verbal or physical conduct that denigrates or
shows hostility or aversion towards an individual and that has the purpose or effect
of creating an intimidating, hostile or offensive environment.

What is in it for employees?

• All business decisions shall be considered on merit.
• Every employee should respect each other's opinions and should not treat others
in a harassing or a threatening manner.
• Any employee found to be engaging in any type of unlawful discrimination or
harassment; will be subject to disciplinary action including termination of
employment.
• All employees must refrain from any action or conduct which could be viewed as
prohibited, including offensive and inappropriate behaviour or language at work
and other kinds of harassment.
How should the employees report?
Any employee who believes that he/she has been a victim of discrimination or
harassment, or who has been a witness to any such incident should report to the
Management on the Whistleblow mechanism provided at the last page of this
Handbook.

Tata AIA Life is an equal opportunity Employer. The Company firmly believes in treating everyone with
respect and does not discriminate on the basis of race, colour, caste, religion, ancestry, gender, origin,
age, nationality, disability, military service, marital status or sexual orientation.

05 06
 Whistleblower Policy
Who is a Whistleblower?
Whistleblower is a person who exposes any kind of information or activity that is
deemed illegal, unethical, or inappropriate within an Organisation. The information
of alleged wrongdoing may relate to a violation of the Company's policy, rules,
regulations, or threat to public interest, as well as fraud, and corruption.
• Any employee, agent or third-party associated with us are encouraged to
Whistleblow.
• The Company has a strong Non-Retaliation Policy for all genuine and bona-fide
Whistleblows.

Why is the Whistleblower Policy instituted?

There may be circumstances in which employees may feel uncomfortable in raising
concerns directly with their supervisors. Hence, the Whistleblower Policy provides
a mechanism to raise, in good faith, such issues confidentially and directly with an
independent person in the top Management of the Company.
Conflict of Interest
The identity of the Whistleblower shall be kept confidential. A Whistleblower will not be at a
How to identify Conflict of Interest? disadvantage or treated unfairly or discriminated against for the reason of such Whistleblowing. Any
A conflict of interest, actual or potential may arise, either directly or indirectly in other person assisting in the investigation arising out of Whistleblow will also be protected to the
circumstances such as: same extent as the Whistleblower.
• An employee of Tata AIA Life in his/her personal capacity engages in a business,
relationship or activity that is conflicting with the interests of the Company.
• An employee is in a position to derive a personal benefit or a benefit to any of his/her
relatives by making or influencing official decisions relating to any transaction.
• Any employee who has a financial interest in any firm which is an actual or
potential competitor, supplier, consumer or distributor of the Company.
• An employee, who is in a position to influence a decision with regards to the
Company's business with a supplier or a consumer represented by his/her relative.
• Award of benefits such as an increase in salary, other remuneration or favourable
service/recruitment conditions to a relative of an employee who is in a position to
influence such decisions.
• Business dealings, where the interests of the Organisation or the Group can be
compromised, diluted or defeated.
Employee's Role
Employees are required to make a full disclosure of any interest which they or their
immediate family may have in a business or a company or a third party which is a
competitor, supplier, consumer, distributor of or has any business dealings with
the Organisation to their Reporting Manager and the Compliance Department.
Consequences of violations
If an employee fails to make a disclosure as required and an instance of conflict of
interest arises, suitable disciplinary action may be initiated against the employee.

Any situation that creates, or even appears to create, a conflict of interest between personal interests
and the interests of the Company, must be avoided. An employee of Tata AIA Life shall not engage in any
business relationship, activity, business decisions or business with a Policyholder, Intermediary,
Reinsurer, Prospect, etc., which might detrimentally conflict with the interests of the Company.

07 08
 Anti-Fraud Policy
The Anti-Fraud Policy of the Company covers various elements like prevention,
detection and responding to various types of frauds. Fraud, as defined in the Anti-
Fraud Policy involves intentional dishonest acts committed to secure an unfair or
unlawful gain for oneself or another, or a loss to another, and can include misuse or
conversion of corporate property or resources for personal non-corporate use.

What is in it for employees?

• The Company has a Zero Tolerance approach to any instance of fraud.
• It is expected that all employees, agents, insurance intermediaries, vendors and
interested parties act with honesty and integrity.
• Every employee is expected to be vigilant and is responsible for timely reporting
of suspected frauds.
• All suspected and reported fraud cases will be investigated and disciplinary
actions shall be taken against parties involved.
` Anti-Money Laundering Program
The Anti-Fraud Policy outlines Tata AIA Life's
approach to prevention, detection and The Anti-Money Laundering (AML) Program is a framework towards co-operating
investigation of fraudulent activities. with the administration in fighting the evils of black money.
Tata AIA Life would like its employees, agents and intermediaries to adhere to all the
applicable laws, rules and regulations generally in relation to AML norms and the
specific requirements mentioned in the Policy.

What is Money Laundering?

• Money Laundering is the process by which proceeds of crime are transformed
into legitimate money or other assets.
• Anti-Money Laundering refers to a set of procedures, laws and regulations
designed to stop the practice of generating income through illegal actions.
• Terrorist Financing refers to the processing of funds to sponsor or facilitate
terrorist activity.

What is in it for employees?

• Employees should read and understand the Anti Money Laundering Policy of the
Company and also clear the mandatory AML Test.
• Employees should strictly follow the AML Policy.
• They should follow strict adherence to KYC Procedures, assess risks and report
suspicious activities.
• Any violation of the AML Policy will be viewed as a regulatory violation and will
attract severe disciplinary action.
If you spot it, Report it.
• Suspicious activities/financial transactions, counterfeit currency, etc. should be
reported to aml.officer@tataaia.com

As per Section 4 of the Prevention of Money Laundering Act, 2002, Punishment for Money Laundering
includes: • Rigorous imprisonment for a minimum term of 3 years, which may extend up to 7 years
• Monetary Penalty

09 10
 Consumer Privacy and Data Security Policy
Consumer Privacy, involves the handling and protection of sensitive personal
information that individuals provide in the course of insurance business. Laws have
enforced high standards of data privacy protection of consumer data.
What is in it for employees?
• Every employee shall ensure at all times, the integrity of data or information
furnished to him/her by the Organisation.
• He/she shall be entirely responsible in ensuring that the confidentiality of data is
retained and in no circumstance transferred outside in the course of normal
operations, without necessary approvals.
• Never compromise consumers' trust by disclosing private information, other than
to those with a legitimate business requirement.
• Personal information, if required to be shared under obligation with government
agencies or officials, must be shared only with approval of the Compliance
Department.
• The employee should protect consumer and business data and not misuse the
Prevention of Sexual Harassment Policy same. Unauthorized downloads, printouts or passing data to a third person are
serious violations.
"Sexual Harassment" means unwelcome acts or behaviour (whether directly or by • When misused or inadequately protected, it can result in identity theft, financial
implication), physical contact or advances; a demand or request for sexual favour; fraud and other problems that collectively lead to irreparable loss to the Company
making sexually coloured remarks; showing pornography; or any other unwelcome and further results in regulatory and/or legal action.
physical, verbal or non-verbal conduct of a sexual nature.
We at Tata AIA Life respect the personal information of employees and consumers. Access to
Some examples of behaviour that constitute sexual harassment: personal information of employees and consumers is only authorized for appropriate personnel with
• Making sexually suggestive remarks or teasing related to a person's body or a legitimate reason to access such information.
appearance.
• Offensive comments or jokes.
• Displaying offensive pictures, posters, texts.
• Intimidation, threats or blackmail around sexual favours.
• Physical contact such as touching inappropriately.
• Stalking an individual.
• Abuse of authority or power to seek sexual favours.
Who can register a complaint?
The aggrieved person, who alleges to have been subject to any act of sexual
harassment can raise the complaint.

How to raise a complaint?

Complaints must be reported on posh@tataaia.com or on the Whistleblowing
mechanism provided at the last page of this Handbook.

Sexual Harassment at workplace can be in the form of Visual or Verbal or Written acts or a combination
of these. Tata AIA Life has a ZERO TOLERANCE policy towards Sexual Harassment at the workplace and
offenders will face strict punitive action. In case of frivolous/false allegations, the Company may take
necessary action on the complainant.

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 Social Media Policy
Tata AIA Life's Social Media Policy is applicable to all employees, agents, business
associates, contractual consultants (retainers), academic interns associated and
third parties performing services on behalf of Tata AIA Life.

What is in it for employees?

• Only few nominated officials are authorized to represent the Organisation on
social media. Any representation by any unauthorized person is a violation of the
Code of Conduct.
• Do not entertain/respond to any media/or address social media queries, on your
own. Consult Corporate Communications and the Compliance Department.
• Whether you publish a personal blog or use any other form of social media, make
it explicitly clear that the views and opinions you have presented are personal and
that the Organisation does not subscribe to your views.
• Be cautious and careful not to mix your personal and business lives, and keep in
mind at all times the global audience of social media.
• Personal participation on social media, should in no way be done in a manner Gifts and Entertainment Policy
prejudicial to the interest of the Company.
• Do not refer financials, achievements, strategies, or other confidential information What is a Gift?
of the Organisation on social media. • A gift is anything of value and includes tangible items and/or intangible benefits
• Use of social media for grievance redressal related to business is prohibited. and rights that are not generally available.
• A "gift" also includes meals, entertainment, hospitality, vacations, trips, use of vacation
Reporting social media crisis - very crucial! homes, tickets to sporting or music events, outings, vendor familiarization trips, and
Every employee of Tata AIA Life is a brand custodian and as such is responsible for safeguarding the use of recreational facilities.
interest of the Company. Any damaging or negative comment in the social space must immediately
be brought to the notice of your superior or the Communications Team at corpcomm@tataaia.com. What is in it for employees?
This is very critical as it will define how effectively the Organisation manages to avert a potential crisis • Offering gifts in order to win or keep business is unethical and, in many cases, illegal.
before any damage is caused to individuals, public, the business or the Company's reputation.
• No person should accept or solicit any personal benefit from anyone in the course
of business in a manner that might compromise, or appear to compromise their
objective assessment.
• Gifts received by any employee of the Organisation should promptly and humbly
be returned with gratitude.
• If declining a gift would be offensive or hurt a business relationship, accept the gift
on behalf of Tata AIA Life and submit a written gift report to your reporting
manager within 30 days or to the Compliance Officer on compliance@tataaia.com.
Managers are responsible for collecting gift reports and filing them with the
Compliance Department.
• Gifts of cash/cash equivalents must never be accepted. In case the gift contains
perishable food items like sweets, chocolates, etc. the same must be distributed
amongst employees, with a request to the person offering such gift to avoid such
future practices.
• As a general guide, the giving or receiving of gifts or hospitality up to R 2,500/- may be
acceptable if it meets all the conditions as given in the Gifts and Entertainment Policy.

Modest gifts and appropriate entertainment can help strengthen business relationships, but these
business courtesies, whether given or received by Tata AIA Life employees, must never improperly
influence business decisions.

13 14
 Anti-Bribery and Anti-Corruption Policy
What is bribery?
Bribery means giving, offering or receiving an improper benefit with the intention of
influencing the behaviour of someone to obtain or retain a commercial advantage.
Bribery can take a variety of forms – offering money or money's worth.
What is corruption?
Corruption is dishonest behaviour by a person or an Organisation entrusted with a
position of authority, often to acquire illicit benefit.
What is in it for employees?
• It is unlawful to offer to give/give bribes for the purpose of obtaining or retaining
business or obtaining an unfair advantage in any business dealing or transaction
and Tata AIA Life employees must never use improper means to influence
another's business judgement.
• No Tata AIA Life employee, agent, or independent contractor may provide bribes
Anti-Trust and Fair Competition Policy or rebates or other improper benefits to another person in order to obtain or
retain business or an unfair advantage in any business interaction that involves
Tata AIA Life competes vigorously and fairly across the industry. We seek to Tata AIA Life, our consumers or employees.
maintain and grow our business through superior products and services - not
through improper or anti-competitive practices. We strive to understand and Who can raise a complaint?
comply with Competition and Anti-Trust laws. Any employee may report concerns or Whistleblow any violations in line with the
Whistleblower Policy of the Company.
What is in it for employees?
• Compete vigorously and lawfully in every market in which Tata AIA Life The Anti-Bribery and Anti-Corruption Policy expressly prohibits any employee of the Company from
participates, making all business decisions independently in the best interest of indulging in any corrupt practices with any public/government official/political party or organisation
Tata AIA Life. and any private individual. Bribery and Corruption in any form and manner will not be tolerated. All
• Comment on competitors or their products or services based only on factual facilitation payments and kickbacks are corrupt payments, and any such payment in the course of
our Company's business is strictly forbidden.
information.
Guidance to Employees
• Don't agree formally or informally with a competitor to fix prices or other terms of
sale or allocate consumers, markets, or territories.
• Don't discuss with a competitor on prices, consumers, sales, commissions, and
terms of sale, profits, margins, costs, marketing plans or other competitively
sensitive information.
• Don't attend meetings with competitors at which competitively sensitive
information, including the subjects mentioned in the above two points, are
discussed.
• Don't agree with others outside of Tata AIA Life, as to which suppliers or consumers
to do business with.

Employees who are unsure of appropriate practices should consult with the Compliance Department
for additional information and clarification.

15 16
 Political Activities Acknowledgement
Tata AIA Life is committed to and supports a functioning democratic Constitution I acknowledge that I have read the Tata AIA Life Code of Conduct and have access
and system with a transparent and fair electoral system in India. to all the Policies referred to in this Handbook.
The Company shall not support, directly or indirectly, any specific political party or
candidate for political office. I acknowledge that as a Tata AIA Life employee, I am expected to comply with the
Tata AIA Life Code of Conduct and failure to do so may subject me to disciplinary
What is Tata AIA Life's political alignment?
action, up to and including termination (and loss of employee benefits) and if
• The Company's conduct shall preclude any activity that could be interpreted as
mutual dependence/favour with any political body or person. applicable, to criminal and/or civil proceedings.
• The Company shall not offer or give any Company funds or property as donations, I understand that if I have a concern about a violation of the Tata AIA Life Code of
directly or indirectly, to any specific political party, candidate or campaign.
Conduct, I must promptly report the violation using the Whistleblow mechanism.
• Tata AIA Life employees may in their personal capacity participate in community
affairs and may support the political party or candidate of their choice, pursuant to
the rights bestowed to the citizens of India under the Constitution of India.

What is in it for employees?

• A Tata AIA Life employee, wishing to run for a political office or accept a political
appointment, must obtain prior written approval from the Compliance
Signature
Department and the Managing Director & CEO.
• Tata AIA Life employees are not permitted to use Tata AIA Life's name in Date DD/MM/YYYY
connection with any political campaign other than to state that they are employed
by or associated with Tata AIA Life. Name
• Tata AIA Life funds or any other Tata AIA Life asset shall not be used for any Emp ID
political purposes.
• It is important that personal political activities or interests do not conflict with Tata AIA Life Insurance Company Limited
responsibilities at Tata AIA Life or imply Tata AIA Life's support.
Department
• Specifically, Tata AIA Life's name should never be used by employees running for
a political office. Address

Holding or campaigning for political office by Tata AIA Life employees must not create, or appear to
create, a conflict of interest with Tata AIA Life duties.

17 18
 Notes Notes

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 Notes Notes

Tata AIA Life Compliance Handbook 2018

has been printed on Recycled Paper

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