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Exhibit 14
WHITE MOUNTAINS INSURANCE GROUP, LTD.
CODE OF BUSINESS CONDUCT
INTRODUCTION
It is the policy of White Mountains Insurance Group, Ltd. and its
subsidiaries (the "Company") to be lawful and highly-principled in all our
business practices.
This Code of Business Conduct (this "Code") applies to all directors,
officers, and employees of the Company (collectively, "Covered Persons") and
covers a wide range of business practices and procedures. In addition, the
Company expects consultants and advisors to the Company to adhere to the
relevant principles of this Code in connection with their activities for the
Company. This Code does not purport to address every issue or situation that may
arise, but sets out basic principles that should govern the day-to-day business
behavior of Covered Persons. All Covered Persons must conduct themselves
accordingly and seek to avoid even the appearance of improper behavior. If
something seems improper, it likely is. The Company expects each Covered Person
to review this Code and to follow both the letter and spirit of the standards
and policies contained herein. Always remember: if you are unsure of what to do
in any situation, seek guidance before you act.
All Covered Persons are expected to seek the advice of their supervisor,
manager or other appropriate persons within the Company when questions arise
about issues discussed in this Code and any other issues that may implicate the
standards or integrity of the Company or any Covered Person. Compliance
procedures are set forth in Section 13 of this Code.
Taking actions to prevent problems is part of the Company's culture. If
you observe possible questionable or illegal conduct you are encouraged to
report your concerns. If you report, in good faith, what you suspect to be
illegal or improper activities, you should not be concerned about retaliation
from others. Any Covered Persons involved in retaliation will be subject to
serious disciplinary action by the Company.
Those who violate the standards in this Code will be subject to
disciplinary action, including dismissal for cause. COVERED PERSONS WHO FIND
THEMSELVES IN A SITUATION WHICH THEY BELIEVE MAY VIOLATE OR LEAD TO A VIOLATION
OF THIS CODE, SHOULD FOLLOW THE GUIDELINES DESCRIBED IN SECTION 13 OF THIS CODE.
1. COMPLIANCE WITH LAWS, RULES AND REGULATIONS
The Company shall transact its business in compliance with all applicable
laws, rules and regulations.
2. CORPORATE OPPORTUNITIES
Covered Persons owe a duty to the Company to advance its legitimate
interests when the opportunity to do so arises. Covered Persons are prohibited
(without the consent of the Board of Directors or a designated committee
thereof) from (1) taking for themselves personally opportunities that are
discovered through the use of corporate property, information or their position,
(2) using corporate property, information or their position for personal gain
and (3) competing with the Company directly or indirectly. The Company
recognizes that the guideline
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in this clause (3) of the prior sentence should not restrict Covered Persons who
are not employed by the Company ("Outside Persons"). In the case of directors of
the Company, these principles are intended to be identical to the comparable
fiduciary obligations directors already owe the Company.
3. CONFLICTS OF INTEREST
A "conflict of interest" exists when a person's private interest
interferes in any way with the interests of the Company.
A conflict situation can arise when a Covered Person takes actions or has
interests that may make it difficult to perform his or her Company work
objectively and effectively. Conflicts of interest also arise when a Covered
Person or a member of his or her family, receives improper personal benefits
(including personal loans, services or payment for services that the person is
performing in the course of Company business) as a result of his or her position
in the Company or gains personal enrichment through access to confidential
information.
Conflicts of interest can arise in many common situations, despite one's
best efforts to avoid them. Covered Persons are encouraged to seek clarification
of, and discuss questions about, potential conflicts of interest with someone in
the Company's Legal Department. Covered Persons may also contact the Company's:
Code of Business Conduct Compliance Officer:
Tel: (603) 640-2200
Fax: (603) 640-2250
Any Covered Person who becomes aware of a conflict or potential conflict
should bring it to the attention of a supervisor, manager or other appropriate
persons within the Company.
4. INSIDER TRADING
There are instances where Covered Persons have information about the
Company, its subsidiaries or affiliates or about a company with which we do
business that is not known to the investing public. Such inside information may
relate to, among other things: plans; new products; mergers, acquisitions or
dispositions of businesses or securities; problems facing the Company or a
company with which we do business; reserves; profitability; negotiations
relating to significant contracts or business relationships; significant
litigation; or financial information.
If the information is such that a reasonable investor would consider the
information important in reaching an investment decision, then the Covered
Person who holds the information must not buy or sell Company securities, nor
provide such information to others, until such information becomes public.
Further, Covered Persons must not buy or sell securities in any other company
about which they have such material non-public information, nor provide such
information to others, until such information becomes public. Covered Persons
who involve themselves in illegal insider trading (either by personally engaging
in the trading or by disclosing material non-public information to others) will
be subject to immediate termination. The Company's policy is to report such
violations to the appropriate authorities and to cooperate fully in any
investigation of insider trading.
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The Company has additional, specific rules that govern trades in Company
securities by directors, officers and employees. Please refer to the Company's
Insider Trading Policy.
Covered Persons may need assistance in determining how the rules
governing inside information apply to specific situations and should consult
someone in the Company's Legal Department or the Company's Code of Business
Conduct Compliance Officer.
5. COMPETITION AND FAIR DEALING
Our policy is to compete vigorously, aggressively and successfully by all
legal means in today's increasingly competitive business climate and to do so in
compliance with all applicable competition, fair dealing and other laws in all
the markets in which we operate. Stealing proprietary information or trade
secret information or inducing such disclosures by past or present employees of
other companies is prohibited. Each Covered Person should endeavor to deal
fairly with the Company's customers and employees.
The antitrust laws of many jurisdictions are designed to preserve a
competitive economy and promote fair and vigorous competition. All Covered
Persons are required to comply with these laws and regulations. Covered Persons
involved in marketing, sales and purchasing, contracts or in discussions with
competitors have a particular responsibility to ensure that they understand our
standards and are familiar with applicable competition laws. Because these laws
are complex and can vary from one jurisdiction to another, Covered Persons
should seek the advice of the Company's Legal Department when questions arise.
6. GIFTS AND ENTERTAINMENT
The purpose of business gifts and entertainment in a commercial setting
is to create good will and sound working relationships, not to gain unfair
advantage with customers. No gift or entertainment should ever be offered,
given, provided or accepted by any Covered Person, family member of a Covered
Person or agent unless it: (1) is consistent with customary business practices,
(2) is not excessive in value, (3) cannot be construed as a bribe or payoff and
(4) does not violate any laws or regulations. Please discuss with your
supervisor any gifts or proposed gifts unless you are certain they are
appropriate.
7. DISCRIMINATION AND HARASSMENT; HUMAN RESOURCES PRACTICES
We are firmly committed to providing equal employment opportunities to
all individuals and will not tolerate any illegal discrimination or harassment.
Examples include derogatory comments based on age, race, gender or ethnic
characteristics and unwelcome sexual advances or comments. This policy extends
to all areas of employment including hiring, training, compensation, promotion,
discipline, transfer, layoff, termination and all other items and conditions of
employment. All Covered Persons shall be treated with respect and consideration
from the Company and must treat others in the same manner.
All levels of supervision are responsible for monitoring and complying
with the Company's policies and procedures for handling complaints concerning
harassment or other forms of unlawful discrimination. Because employment-related
laws are complex and vary from state to state and country to country,
supervisors should obtain the advice of the Company's Legal Department whenever
there is any doubt as to the lawfulness of any proposed action or inaction.
The Company strives to provide each employee with a safe and healthy work
environment. Each Covered Person has responsibility for maintaining a safe and
healthy
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workplace for all Covered Persons by following safety and health rules and
practices and reporting accidents, injuries and unsafe equipment, practices or
conditions.
Violence and physically threatening behavior is expressly prohibited.
Covered Persons should report to work in condition to perform their duties, free
from the influence of illegal drugs or alcohol. The use of alcohol or illegal
drugs in the workplace will not be tolerated and may result in immediate
termination.
8. RECORD-KEEPING, RETENTION AND DESTRUCTION
Many persons within the Company record or prepare some type of
information during their workday, such as time cards, financial reports,
accounting records, business plans, environmental reports, injury and accident
reports, expense reports, and so on. Many people, both within and outside the
Company, depend upon these reports to be accurate and truthful for a variety of
reasons. These people include our Covered Persons, governmental agencies,
auditors and the communities in which we operate. Also, the Company requires
honest and accurate recording and reporting of information in order to make
responsible business decisions. We maintain the highest commitment to recording
information accurately and truthfully.
All financial statements and books, records and accounts of the Company
must accurately reflect transactions and events and conform both to required
legal requirements and accounting principles and also to the Company's system of
internal accounting. As a Covered Person, you have the responsibility to ensure
that false or intentionally misleading entries are not made by you, or anyone
who reports to you, in the Company's accounting records. Regardless of whether
reporting is required by law, dishonest reporting within the Company, or to
organizations or people outside the Company, is strictly prohibited. All Covered
Persons that are responsible for financial or accounting matters are also
required to ensure the full, fair, accurate, timely and understandable
disclosure in all periodic reports required to by filed by the Company with the
Securities and Exchange Commission. This commitment and responsibility extends
to the highest levels of our organization, including our chief executive
officer, chief financial officer and chief accounting officer.
The Company establishes retention or destruction policies in order to
ensure legal compliance and also to accomplish other objectives, such as
preserving intellectual property and cost management. The Company expects all
Covered Persons to comply with any applicable records retention or destruction
policy, provided that all Covered Persons should note the following general
exception to any record retention or destruction policy. If any Covered Person
believes, or if the Company informs him or her, that the Company's records are
relevant to any litigation or potential litigation (i.e. a dispute that could
result in litigation), he or she must preserve those records until the Company's
General Counsel or another authorized legal officer determines the records are
no longer needed. This exception supersedes any previously or subsequently
established retention or destruction policy for those records.
The Company recognizes that the guidelines in this Section 8 are not
applicable to Outside Persons.
9. CONFIDENTIALITY
Covered Persons must maintain the confidentiality of confidential
information entrusted to them by the Company or companies, organisations or
entities that have or may have a business relationship with the Company, except
when disclosure is expressly authorized by the Company or required by laws or
regulations. Confidential information includes all non-public information that
might be of use to competitors, or harmful to the Company or companies,
organisations or
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entities that have or may have a business relationship with the Company, if
disclosed. It also includes information that others that have a business
relationship with the Company have entrusted to us. The obligation to preserve
confidential information continues even after employment ends.
Covered Persons should guard against unintentional disclosure of
confidential information and take special care not to store confidential
information where unauthorized personnel can see it, whether at work, at home,
in public places or elsewhere. Situations that could result in inadvertent
disclosure of such information include: discussing confidential information in
public (for example, in restaurants, elevators or airplanes); talking about
confidential information on mobile phones; working with sensitive information in
public using laptop computers; and transmitting confidential information via
fax. Within the workplace, do not assume that all Covered Persons should see
confidential information.
10. PROTECTION AND PROPER USE OF COMPANY ASSETS AND PROPRIETARY INFORMATION
Collectively, Covered Persons have a responsibility for safeguarding and
making proper and efficient use of the Company's property. Each of us also has
an obligation to prevent the Company's property from loss, damage, misuse,
theft, embezzlement or destruction. Theft, loss, misuse, carelessness and waste
of assets have a direct impact on the Company's profitability and may jeopardize
the future of the Company. Any situations or incidents that could lead to the
theft, loss, misuse or waste of Company property should be reported immediately
to the security department or to your supervisor or manager as soon as they come
to your attention.
The Company depends on intellectual property, such as business and
marketing plans, databases, records, salary information and any unpublished
financial data and reports, for its continued vitality. If intellectual property
is not protected, it becomes available to other companies that have not made the
significant investment that the Company has made to produce this property and
thus gives away some of the Company's competitive advantage. All of the rules
stated above with respect to confidential information apply equally to
proprietary information.
11. ILLEGAL PAYMENTS; RELATIONSHIPS WITH GOVERNMENT PERSONNEL
Improper payments, whether illegal political contributions, bribery of
domestic or foreign officials, or similar acts, are contrary to the policy of
the Company, and funds and resources of the Company shall not be used directly
or indirectly for such purposes.
The U.S. Foreign Corrupt Practices Act prohibits giving anything of
value, directly or indirectly, to officials of foreign governments or foreign
political candidates in order to obtain or retain business. It is strictly
prohibited to make illegal payments, including illegal political contributions,
of any kind to government officials or political candidates of any country.
In addition, many jurisdictions have laws and regulations regarding
business gratuities which may be accepted by government personnel. For example,
business courtesies or entertainment such as paying for meals or drinks are
rarely appropriate when working with government officials. Gifts or courtesies
that would not be appropriate even for private parties are in all cases
inappropriate for government officials. Please consult the Company's Legal
Department for more guidance on these issues.
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12. WAIVERS OF THE CODE OF BUSINESS CONDUCT: APPLICABILITY
Any waiver of this Code for executive officers or directors may be made
only by the Board of Directors or the Audit Committee, subject to any applicable
rules or regulations and the Company's Bye-laws.
This Code does not require any changes to contractual arrangements in
effect on the date of its adoption. In addition, participation in investment
opportunities voluntarily offered by the Company shall not be a violation of
this Code provided that such investment is on the same terms as are negotiated
and accepted by unaffiliated third party investors participating in the
transaction.
13. REPORTING OF ILLEGAL, IMPROPER OR OTHER QUESTIONABLE BEHAVIOR OR
ACCOUNTING/AUDITING COMPLAINTS
Covered Persons are expected to conduct themselves in a manner
appropriate for their work environment, and are also expected to be sensitive to
and respectful of the concerns, values and preferences of others. Whether an
employee, contractor, supplier or otherwise a member of the Company family,
Covered Persons are encouraged to promptly report any practices or actions they
believe to be inappropriate.
This Code describes the procedures generally available for discussing and
addressing business conduct issues that arise. Speaking to the right people is
one of a Covered Person's first steps to understanding and resolving what are
often difficult questions. As a general matter, if a Covered Person has any
questions or concerns about compliance with this Code or is just unsure of what
the "right thing" is to do, the Covered Person is encouraged to speak with his
or her supervisor, manager or other appropriate persons within the Company. If a
Covered Person does not feel comfortable talking to any of these persons FOR ANY
REASON, the Covered Person should call someone in the Company's Legal
Department, the Company's Code of Business Conduct Compliance Officer, or report
the issues or concerns through the Company's anonymous web based or toll free
telephone reporting system. Each of these offices has been instructed to
register all complaints, brought anonymously or otherwise, and direct those
complaints to the appropriate channels within the Company.
ACCOUNTING/AUDITING COMPLAINTS: The law also requires that the Company
have in place procedures for addressing complaints concerning auditing issues
and procedures for Covered Persons to anonymously submit their concerns
regarding accounting or auditing issues. Complaints concerning accounting or
auditing issues will be directed to the attention of the Company's Audit
Committee, or the appropriate members of that committee.
Covered Persons may direct issues or complaints directly to the
Company's Code of Business Conduct Compliance Officer or indirectly through the
Company's confidential, anonymous web based or toll free telephone reporting
system.
DIRECTLY TO THE CODE OF BUSINESS CONDUCT COMPLIANCE OFFICER:
PRIVATE AND CONFIDENTIAL
White Mountains Insurance Group, Ltd.
80 South Main Street
Hanover, NH 03755
Attn: Code of Business Conduct Compliance Officer
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VIA THE COMPANY'S ANONYMOUS WEB BASED REPORTING SYSTEM BY LOGGING ONTO:
www.ethicspoint.com
VIA THE COMPANY'S ANONYMOUS TOLL FREE REPORTING SYSTEM BY CALLING:
Tel: 1-800-788-1157
Fax: 1-800-788-1187
The Company's anonymous reporting system is maintained and operated by
EthicsPoint, Inc., an unaffiliated service provider. All issues or complaints
submitted via the anonymous reporting system will be forwarded to the Company's
General Counsel for resolution.
For direct access to the Company's Audit Committee, Covered Persons may
direct their auditing and accounting related issues or complaints to:
PRIVATE AND CONFIDENTIAL
Mr. Lowndes A. Smith
Chairman of the Audit Committee
White Mountains Insurance Group, Ltd.
80 South Main Street
Hanover, NH 03755
Also, as discussed in the Introduction to this Code, Covered Persons
should know that if they report in good faith what they expect to be illegal or
improper activities, they should not be concerned about retaliation from others.
Any Covered Persons involved in retaliation will be subject to serious
disciplinary action by the Company. Furthermore, the Company could be subject to
criminal or civil actions for acts of retaliation against Covered Persons who
"blow the whistle" on U.S. securities law violations and other federal offenses.
14. COOPERATION IN INTERNAL INVESTIGATIONS
Covered Persons are expected to cooperate fully in all internal
investigations of any kind initiated by the (i) Board of Directors or any
Committee appointed by the Board, (ii) senior management, (iii) internal
auditors, (iv) external auditors, and (v) any regulatory or law enforcement
agency. Covered Persons are expected to respond to all inquiries with honesty
and integrity.
15. CONFLICT WITH SUBSIDIARY COMPANY BUSINESS CODES OF CONDUCT AND CONFLICTS
OF INTEREST POLICIES
The Company recognizes that one or more of its operating subsidiaries
have codes of business conduct and conflicts of interest policies that have been
approved by their respective boards of directors. If any provision contained in
this Code conflicts with any provision contained in subsidiary company's code of
business conduct and conflict of interest policies, the provision in this Code
shall prevail. This Code may be approved for adoption by the board of directors
of any of the Company's subsidiaries.
16. ADOPTED BY THE BOARD OF DIRECTORS
Adopted by the Board of Directors of White Mountains Insurance Group, Ltd.
effective as of February 26, 2004.
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