商业行为准则

1、Approving Body Oversight DepartmentAnnual Review DateApproving Body Oversight DepartmentAnnual Review Date总则/General Provisions目录Table of Contents合法合规/ Compliance with Laws and Regulations利益冲突/Conflict of Interest礼品与利益/Gifts and Favors外部行为和董事任职/Outside Offices and Directorships内幕信息/Insider Informati

2、on保密信息/Confidential Information隐私权指引/Right to Privacy Guidelines计算机系统安全/ Computer Systems Security雇用实践/Employment Practices环境/Environment交易实践/Trade Practices保险实践/Insurance Practice及时沟通/Prompt Communications外部人员与机构关系处理/Dealings with Outside Persons and Organizations记录和报告/Records and Reporting公司资金/Com

3、pany Funds遵守准则/Compliance with the Code总则/General Provisions本准则广泛陈述了能使 xxx（以下统称“XXX”）持续成为最佳诚信公司的商业行为和个人道德类型。如大家所知，公司是所有员工行为的共同载体。本准则提供了全体员工需遵守的正式行为指引。The Code sets out, in very broad terms, the type of business conductand personal ethics which is required of you in order for XXX(hereinafter XXX) to

4、continue to be regarded as a company of theutmost integrity. As you well know, the company is a reflection of the conduct of all of us who manage its affairs. The Code is a means of providing formal guidelines on the behavior which is expected of all our staff.XXX 在业务行为方面致力于达到法律和道德标准的最高准绳，希望成为并被认可为良

5、好的企业法人和能够公平、公正地对待客户与员工的企业。本准则的目的是帮助每一位员工了解应遵循什么样的行为方式，以及建立最低行为标准。本准则适用于全体员工以及代理人员（以下统称“员工”）。直系亲属” 包括配偶、父母、岳父岳母和子女。所有员工要认真学习准则，依据准则行事，这样，XXX 才能持续地获得广大客户与公众的普遍信任和信心。XXX is committed to the highest level of legal and ethical standards in the conduct of its business and wishes to be and be known as a go

6、od corporate citizen and a company which deals fairly and equitably with its clients and employees. This Code of Business Conduct is intended to assist each member of the organization to know what is expected, and it sets out our minimum standards of behavior. The Code applies to all employees of XX

7、X and agents (hereafter “employee”). The “immediate family” includes spouse, parents and children. employees are required to study the Code carefully and to be guided by its principles so that XXX may continue to earn the trust and confidence of its clients and the public at large.以下是本准则的基本原则：The fo

8、llowing is the general provisions of the Code:遵守当地法律法规和职业行为标准；Wewillcomplywithallapplicablelaws,regulationsand professional conduct standards in every district in which we 客户需要；We will provide high standards of service to all of our customers, respecting their interests and aiming to meet their need

9、s with the services we provide to them.避免个人或财务的利益冲突，诚实道德地处理冲突并进行恰当披露；We will avoid personal or financial conflicts of interest and handle actual or perceived conflicts honestly and ethically, making all appropriate disclosure.遇而妥协；We will not be compromised through any preferential treatment given t

10、o or accepted from customers, suppliers or other people with we deal.诚实、准确地与利益相关者沟通；We will communicate honestly and accurately with all of our stakeholders.对我们所在地区的社会与经济做出贡献。We will contribute to the social and economic wellbeing of the communities where we have operations.公平对待员工，支持他们持续学习和不断发展。We w

11、ill treat our people fairly and support their ongoing learning and development.合法合规/ Compliance with Laws and RegulationsXXX 及其员工必须遵守中国的法律法规。XXX 业务需遵守非常复杂及多变的法律法规，任何员工在无法确定法律法规的适用性和解释时，应从合规与运营风险部或法务部获得帮助。XXX and its employees must comply with all laws and regulations governing XXXs business in China

12、 in which we operate. Our operations are subject to very complex and changing laws and regulations and, if employee is in doubt about the application or interpretation of any legal and regulatory requirement, the matter should be referred to the Compliance & Operational Risk and Legal.利益冲突/Conflict

13、of InterestXXX益相冲突。Employees are required to see that actions taken and decisions made by them within their jurisdiction are free from the influence of any interest which might reasonably be regarded as conflicting with the interests of XXX and its clients.相应地，必须恪守以下原则：In this connection the followi

14、ng principles must be adhered to:XXX应该避免任何与其工作职责发生或可能发生利益冲突的情形。Personal or outside activities must not conflict, either directly or indirectly, with an employees duties to XXX. Employees should, therefore, avoid situations in which their personal interests conflict, or are likely to conflict, with t

15、heir duties to XXX.XXXNo employee should participate in a personal, business or investment activity outside XXX which would tend花费过多的时间和注意力从而无法以最佳状态为其在XXX 的岗位务；To create an excessive demand upon his or her time and attention and thus deprive XXX of his or her best efforts the job; or造成利益冲突 - 这是指，可能妨

16、碍其做出对 XXX判断的义务，利益或其他干扰事项。To create a conflict of interest - that is, an obligation, interest or distraction which would interfere with the independent exercise of his or her judgment in XXXs best interests.XXX正在酝酿的业务发生或具有潜在利益冲突时，必须及时地向其直接主管汇报。An employee who has a conflicting or possibly conflicting

17、 interest between his or her personal, business or other outside activities and any business interest of XXX or any transaction which he or she knows under consideration by XXX must make timely disclosure in connection to his or her immediate superior.礼品与利益/Gifts and FavorsXXX的礼品和好处。赠与或收受礼品和好处必须符合 X

18、XX断的情形发生。Employees and the members of their immediate family must neither accept nor be a party to giving gifts and favor from or to any one with whom XXX is doing or negotiating business. The activities of gift and favor offering and receiving must comply with the Gift Policy of XXX. This rule is n

19、ot intended to prohibit normal and widely accepted ethical business practices such as business meals and receptions, including mementos or gifts of nominal value. However, anything which could beconsidered as a payoff or secret compensation is prohibited. If in the gift or favor should be avoided. I

20、n particular, employees should guard against any situation where their business judgment might be influenced by a feeling of gratitude.XXXXXX与优惠。The selection of suppliers, contractors and any other firms individuals retained by XXX for the purchase of goods or services is to be made in accordance w

21、ith XXXs purchasing policy and solely on grounds of the best available price, superior performance and integrity. Gifts and favors and other personal benefits or advantages must not beaccepted in consideration of the granting of such contracts or the purchase of goods or services.外部行为和董事任职/Outside O

22、ffices and DirectorshipsXXXXXX良好声誉，应该得到鼓励。Employees of XXX have a very real responsibility for good public relations. Their readiness to help with charitable and educational activities has brought great credit to XXX and should be broadened and encouraged.XXXXXXXXX抱有疑问，应立即向部门负责人汇报。In some cases, it

23、may be consistent with XXXs interests for employees to serve on the boards of business enterprises. Prior approval to serve on the board of an outside business enterprise must be obtained from General Manager. However, any outside activities which impair individuals ability to attend to company duti

24、es, or which conflict with his or her duties on behalf of XXX, should be avoided. If there is any question about any such outside activities being contemplated by an employee, the head responsible for his or department should be promptly informed.内幕信息/Insider Information员工不能使用自己在雇用期间获得的尚未公开的重要信息（一般称

25、之为“内幕信 息”）为是违法行为，会给个人和公司带来严重后果。Employees shall not use material information gained in the course of employment (commonly referred to as insider information) and which is not generally known to the public for personal gain or the advantage of others such as friends and relatives. Passing insider info

26、rmation to another person or company is illegal and an employee who does so could expose himself or herself and/or company to heavy damages.“重要信息”包括重要事实以及涉及某企业当前或未来的财务状况、产品与服务、证券市场、XXX 针对该企业的投资及投资意向等有关的重要变化。未经广泛披露的，或者以一个具备正常理性的人在决定是否买卖或者持有证券时作为重要因素考虑的信息都被认定为是重要信息。Material information may include inf

27、ormation about a material fact or material change regarding the financial condition, present or future, a business enterprise, its products and services, the market for its securities or XXXs investments or investment intentions with respect such enterprise. Information will be deemed material if it

28、 has not been generally disclosed and a reasonable person would consider it important in deciding whether to purchase, sell or hold any securities. 员工不允许利用重要信息为自己或其直系亲属的账户交易有价证券。No employee may trade in securities for his or her account or account of any member of his or her immediate family on the

29、basis of material information.XXXXXX证券。An employee who knows or has reason to believe that XXX is purchasing, selling or actively negotiating with respect to a particular security other investment in a business may not purchase or sell, directly or indirectly, the securities of that business for his

30、 or her own account or that of any member of his or her immediate family until after the completion of such purchase or sale by XXX.XXXXXX易往来的机构获得任何超出普通投资人应该得到的利益。No employee and any member of his or her immediate family can benefit more than ordinary investors from the security brokers of XXX and a

31、ny other institutions which have security transactions with XXX.保密信息/Confidential InformationXXX信息的规定。Personal information forms the basis of the life and health insurance industry. Consequently, XXX must ensure adherence to rules governing the protection of this confidential and sensitive informati

32、on.XXXXXX突甚至交易失败。In addition, all information acquired by employees during the course of their employment concerning XXXs business, including its plans, business strategies, product development plans, pricing, systems investments as well as all documentation in that connection or that is not general

33、ly known to the public must be treated as confidential. Such information is not to be disclosed outside of XXX and employees may not use it for the personal advantage of themselves, their families, and associates. The circulation or leaking of some kinds of information could materially weaken XXXs c

34、ompetitive advantage and would, in many instances, give rise to conflicts of interest and even an aborted transaction.隐私权指引/Right to Privacy GuidelinesXXX 经营的保险业务的特点要求公司收集、运用及保管员工、公司个人客户的个人信息，并依法或经授权向第三方披露。员工的个人信息遵循与客户个人信息同样的隐私权指引。必须审慎掌握尺度以平衡对信息及个人隐私权、公正性以及干预最小化等方面的需求，并采取必要的预防措施保护这些利益。为此目标，XXX 遵守以下原

35、则：The nature of the business of insurance as carried on by XXX requires that XXXcollect, use and retain personal information about its employees and those individuals to and through whom XXXs services are provided and to disclose such information to third parties when authorized or required to do so

36、 by law. Personal information about our own employees is subject to the same privacy guidelines as personal information about our customers. XXX must balance carefully its need such information against the individuals right to privacy, the need fairness, and the need to minimize intrusiveness, and t

37、ake necessaryprecautions to protect these interests. To that end, XXX will observe the following guidelines:只能通过合法途径获得个人信息。Only lawful means will be used to collect personal information.避免蓄意拜访、虚假和误导等行为。Pretext interviews and false and misleading practices will be avoided.告知个人。The purpose for which p

38、ersonal information is collected from an individual will be specified on or before the collection of information, and any change of purpose will be communicated to individual.告知个人，XXXIndividual is to be informed that the personal information collected through lawful means will be properly secured.XX

39、X 收集和保存的个人信息属于机密，XXX机密性。Personal information that is collected and retained will be considered to be confidential and proper safeguards will be provided to protect that confidentiality.XXXXXXEvery reasonable effort will be made to ensure that personal information collected, used, retained or disclos

40、ed is accurate, relevant to the effective conduct of XXXs business, timely complete. An individual may correct or clarify personal information regarding him or her retained by XXX.对个人信息的披露和使用不得超出向个人说明的目的, 除非:Personal information will not be disclosed or used for purposes other than those specified t

41、o the individual, except:获得个人同意; 或With the consent of the individual concerned; or依据法律需要; 或Where required by law; orXXXWhere reasonably necessary, to determine eligibility for an insurance benefit or, to protect the interests of XXX against criminal activity, fraud, and material misrepresentation in

42、 connection with an insurance contractXXXXXXXXXXXXAll employees, directors, brokers, intermediaries and other persons or organizations acting for XXX or on its behalf will be required to conform to these guidelines. Intermediaries of XXX who are not employees will be required to sign a contract whic

43、h incorporates these guidelines.计算机系统安全/ Computer Systems SecurityXXXXXXXXX全保管。The security of XXXs computer systems is crucial to the continued success of XXX. Access to our computer resources is restricted and they can only be used in accordance with company policy. Individuals who are granted acc

44、ess have an obligation to keep their passwords confidential and to limit their use of computer systems to authorized businesspurposes. Computer media containing sensitiveinformation are to bekeptin a locked location at all times when not inuse; and all computerdataof a confidential nature, whether i

45、n paper orelectronic form, mustbekept secure at all times.XXXXXX的商业秘密，必须妥善处理。All computer programs and related materials developed by XXX employees within the scope of their employment on behalf of XXX are the property of XXX, constitute valuable and confidential trade secrets, and must be treated a

46、ccordingly.XXXXXX格遵守。Additionally, the proprietary rights of outside firms which provide software to XXX on a licence basis must be protected. All employees are required to protect the confidentiality of such programs and must not participate in their unauthorized duplication or use. In some instanc

47、es employees who have access to such software are required by XXXs licensing arrangements to sign formal confidentiality agreements which must be rigorously observed.雇用实践/Employment Practices在一个认可能力和绩效的挑战性工作环境中建立并且保持一套高效的组织机构是XXX 的政策。开创并保持一种人文环境，使之能够推动和鼓励员工发展、高水平的个人和部门绩效、以及与职级相符的职权授予也是 XXX 的政策。It is

48、 the policy of XXX to establish and maintain an efficient organization in a challenging working environment in which ability and performance are recognized. It is also the policy of XXX to develop and maintain a personnel environment which will promote and encourageopportunities for employee advance

49、ment, high individual and departmental performance levels and the implementation of an organizational hierarchy consistent with delegation of responsibility and accountability.XXX 所有的雇用行为，包括招聘、面试、薪酬及福利都必须依照相关法律法规进行。做出晋升决定必须基于工作绩效所证明的能力。XXX 将遵循所有涉及雇用标准的相关法律，包括法定假日、最低工资，工作时数, 加班工资和产假。All of XXXs emplo

50、yment practices, including recruitment, interviewing, compensation and benefits are to be conducted in accordance with and Regulations. Promotions are to be made on the basis of ability demonstrated by work performance. XXX will also comply with all applicable legislation relating to employment stan

51、dards including statutory holidays, minimum wages, hours of work, holiday entitlement, and maternity leave.任何关于歧视、骚扰或不公平待遇的投诉应该立刻向员工直接上级或人力资源总监报告。Any complaints concerning discrimination, harassment or unfair employment practices should be reported immediately to the employees immediate superior or

52、Human Resources Director.环境/EnvironmentXXX 承诺遵循当地法律法规，通过减少和循环利用废物，安全处理有害垃圾等措施保护环境。XXX is committed to environmental protection through the reduction and recycling of waste and the safe handling and disposal of any materials which may be considered hazardous in accordance with applicable laws and reg

53、ulations.交易实践/Trade PracticesXXX 及其员工应该避免从事任何可能被认为有失公平的交易行为，例如限定价格和其它导致减少竞争、欺诈、误导性宣传，对产品和服务的误导性和欺骗性描述及对其他保险公司的错误陈述等方面的行为。XXX and its employees should avoid doing anything which might be considered as an unfair trade practice. Examples of unfair trade practices include price fixing and other acts whi

54、ch result in lessened competition, false or misleading advertising, misleading or deceptiverepresentations concerning products and services and false statements concerning other insurance companies.保险实践/Insurance Practice除了遵循与交易有关的全部适用法律之外，XXX 还承诺将遵循中国保监会有关公平保险行为方面的一切法令、法规和指引。监管禁止的保险行为包括但不限于：保费和佣金回扣

55、、不当保单替换、展业中进行虚假或误导性的声明或陈述以及对保险合同进行非全面比较。XXX 承诺公平理赔。In addition to complying with all applicable legislation relating trade practices, XXX is committed to compliance with all applicable insurance statutes and regulations and the guidelines of the CIRC with respect to fair insurance practices. Practic

56、es which are prohibited under the regulations include but not limited to: premium and/or commission rebating, improper replacement of insurance policies, making false or misleading statements or representations in the solicitation insurance, and making incomplete comparisons of contracts of insuranc

57、e. XXX is also committed to fair claims settlement practices.及时沟通/Prompt CommunicationsXXX提供达标的服务是每一名员工的责任。信息咨询和客户投诉必须及时处理。It is essential to the continued success of XXX that communications with applicants, policyholders, claimants, governmental authorities, the public and others in the organizatio

58、n be conducted in a complete, accurate and timely manner; and it is the duty of each employee to furnish services that meet responsible standards of performance, efficiency and courtesy. A prompt response must be made to all requests for information and to all complaints.与监管当局、董事会、合规人员，内部与外部审计人员的沟通必

59、须全面、准确和及时。Communications with the governmental authorities, Board of Directors, compliance officers and internal and external auditors on all matters relevant to them must be complete, accurate and timely.外部人员与机构关系处理/Dealings with Outside Persons and OrganizationsXXX司标识、办公用品、供应品及设备等不得用于个人事务。Employee

60、s must take care when communicating on matters not involving company business to separate their personal roles from their corporate positions. Company identification, stationery, supplies and equipment must not be used for personal concerns.员工不得以 XXX 名义就任何 XXX 业务事项发表公开言论。When communicating publicly