AXIS Capital : Code of Business Conduct (Code of Business Conduct 5 13 2026 1 6d6aff)
AXS
Published on 05/18/2026 at 09:23 am EDT
Purpose 1
Compliance with Laws, Rules, and Regulations 2
Whistleblower Policy and Procedures for Making Complaints 2
Conflicts of Interest 3
Purpose
The Code of Business Conduct (the "Code") is intended as a central reference to guide employees, officers and directors of AXIS Capital Holdings Limited and its subsidiaries (the "Company") in day-to-day decision making. This Code will help the Company's employees, officers, and directors recognize and approach ethical issues. The Code defines business procedures and practices that are consistent with our corporate values. It does not cover every situation that could arise; instead, it provides guiding principles that apply to all employees, officers, and directors. These guiding principles hold all of us at the Company to the highest standards of business conduct.
Each employee, officer, and director of the Company is expected to conduct the
Company's business with integrity and to comply with all applicable laws. This includes:
Avoiding situations where personal interests are, or appear to be, in conflict with Company interests.
Protecting and properly using Company assets, including preserving the confidentiality of non-public information and not acting on such information for personal benefit.
Dealing fairly and honestly with all customers, suppliers, competitors, and teammates.
Conducting relationships with public officials and political candidates in compliance with all applicable laws, rules, and regulations.
Being honest, accurate, and fair in all reports, records, and communications.
We must all strive to cultivate a Company culture of honesty and accountability. We are all responsible for ensuring prompt and consistent action against violations of the Code. To that end, all employees, officers and directors of the Company are encouraged to report to the General Counsel what they believe, in good faith, are violations of any law, rule, or regulation, the Code or any other Company policy, whether unintentional or deliberate, by any Company employee, officer or director.
Ethical conduct is not always clear-cut. You should always consult with managers or the General Counsel when in doubt about the best course of action. The Company does not permit retaliation for reports made in good faith.
To assist the Company in ensuring compliance with the Code, each employee, officer, and director is required to certify compliance with the Code annually (in the form attached hereto as Exhibit A).
Compliance with Laws, Rules, and Regulations
The Company intends to operate its business lawfully in every respect. All employees, officers and directors must respect and obey all applicable laws, rules, and regulations. All employees, officers and directors must observe the laws of the cities, states, and countries in which we operate. You are not expected to know the details of the law, but you are expected to know enough to determine when to seek assistance from supervisors, managers, or other appropriate personnel.
For the Company's employees, officers, and directors who reside and work outside of the United States, it is important to note that the references to U.S. laws, rules, and regulations are intended to serve as examples. All employees, officers and directors are required to comply with laws applicable to them and are required to comply with U.S. laws, rules, and regulations to the extent mandated by this Code. However, in the event a law, rule, or regulation conflicts with this Code, you must comply with the local law, rule, or regulation.
Whistleblower Policy and Procedures for Making Complaints
It is the policy of the Company to comply with and require its employees, officers, and directors to comply with all applicable laws, rules, and regulations, the Code, and any other Company policies. The Company has established procedures that govern the process through which employees, officers, directors and others may confidentially report, either openly or anonymously, an actual or potential violation by another person acting on behalf of the Company of any law, rule or regulation, the Code or any other Company policy. This includes the report of information relating to accounting, internal accounting controls or auditing matters. Because these reports are essential to the effective operation of the Company, retaliation against reporting individuals is prohibited. The Company has provided each employee, officer, and director a copy of these procedures in a separate document entitled "Whistleblower Policy."
Employees, officers, directors, and others may report violations or make a complaint, either openly or anonymously, by:
Writing to the Audit Committee Chair or the General Counsel by mail at AXIS Capital Holdings Limited, P.O. Box HM 1254, Hamilton HMFX Bermuda.
Contacting the Audit Committee Chair (i) by telephone via the Company's toll-free hotlines at +1 (844) 948-0411 (within the U.S.) or 0808-234-1294 (within the UK and Northern Ireland) - please refer to Exhibit B for dialing instructions for additional toll-free hotlines.
Contacting the General Counsel (i) by telephone at +1 (212) 835-3067 or (ii) emailing the General Counsel at [email protected].
Using the Company's web-based reporting module at axiscapital.ethicspoint.com.
Conflicts of Interest
A "conflict of interest" occurs when an individual's private interest interferes in any way
or even appears to interfere - with the interests of the Company as a whole. Conflicts of interests, and the appearance of conflicts, are prohibited.
Improper Personal Benefits. Conflicts of interest may arise when an employee, officer, director, or a member of the person's family receives improper personal benefits as a result of the individual's position in the Company. For example:
Loans to, or guarantees of the obligations of, any employee, officer, director, or a member of the individual's family may not be made without the approval of the Company's Board of Directors.
Gifts or favors from potential vendors that are inconsistent with normal business practices are prohibited. (See Part X below for a detailed discussion of gifts and favors.)
Ownership or Financial Interest in Other Businesses. The Company respects the rights of its employees, officers, and directors to manage their affairs and investments and does not wish to impinge upon their personal lives. At the same time, employees, officers, and directors should avoid situations that present a potential conflict between their interests and the interests of the Company. Also, they should pay proper attention to the Company's interests. The Company's employees, officers and directors owe the Company their loyalty and should avoid any interest, investment or association that interferes with the independent exercise of sound judgment in the Company's best interests. Also, any activities that create the appearance of a conflict of interest should be avoided.
To attempt to be too specific in what constitutes a conflict of interest involves the risk of restricting the application of the Code. However, there are obvious situations which most certainly can result in a conflict of interest: having an undisclosed financial interest in a supplier, competitor or customer by an employee or a member of the employee's family; having an undisclosed interest in a transaction in which it is known that the Company is, or may be, interested; or the receipt of undisclosed fees, commission or other compensation from a supplier, competitor or customer of the Company.
Corporate Opportunities. Employees, officers, and directors owe a duty to the Company to advance its legitimate interests when the opportunity so arises. It is improper for employees, officers, and directors to take opportunities discovered through use of corporate property, information, or position for themselves personally. It is also improper for employees, officers, and directors to take or use corporate property, information, or position for personal gain.
In certain specific transactions, the improper use of Company information, property or position may be assumed, and for this reason, these situations should be avoided. For example:
You may not appropriate, for your own advantage, any business opportunity that you discover in the course of your employment or in your capacity as a director.
Disclaimer
Axis Capital Holdings Limited published this content on May 18, 2026, and is solely responsible for the information contained herein. Distributed via Public Technologies (PUBT), unedited and unaltered, on May 18, 2026 at 13:22 UTC.