It is an important responsibility of the Board of Directors to establish appropriate internal control systems. Tokio Marine & Nichido Fire Insurance Co., Ltd. (hereinafter the "Company") has adopted "Basic Policies for Internal Controls" at the Board of Directors' Meeting in accordance with the Companies Act of Japan and its Ordinance for Enforcement, the Business Management Agreement entered into with Tokio Marine Holdings, Inc. (hereinafter "Tokio Marine HD"), and Tokio Marine Group's basic policies established by Tokio Marine HD. The Company has formulated internal control systems based on the following basic policies and has been promoting them properly.

1. System for ensuring proper operations within the Tokio Marine Group (the "Group")

2. System for ensuring the execution of professional duties in accordance with applicable laws, regulations and the Articles of Incorporation

3. System for risk management

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4. System for ensuring efficient execution of professional duties

5. System for preserving and managing information concerning the execution of directors' duties

The Company shall establish its rules for the preservation of documents and other materials. The minutes of important meetings and documents containing material information regarding the execution of duties by the directors and the executive officers shall be preserved and managed appropriately in accordance with such rules.

6. Matters concerning support personnel to the Audit & Supervisory Board Members

7. System of reporting to the Audit & Supervisory Board Members

8. Other systems for ensuring effective audits by the Audit & Supervisory Board Members

Adopted May 12, 2006
Amended December 21, 2007
Amended July 1, 2008
Amended July 1, 2009
Amended April 28, 2010
Amended April 28, 2011
Amended April 27, 2012
Amended July 1, 2013
Amended April 1, 2015