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Introduction to Travelers | 2Q 2016 TRVERM123!

JLEVASSETypewriterthis is a keyword trverm123!

Long-Term Financial Strategy

Meaningful and

sustainable

competitive

advantages

Generation of

top tier earnings

and capital

substantially in

excess of growth

needs

Balanced

approach to

rightsizing capital

and

growing book

value per share

over time

CREATE SHAREHOLDER VALUEObjective: Mid-Teens Operating ROE Over Time

2

3

Enterprise Key Competitive Advantages

Return focused company

Product breadth and specialization

Top 3 player in Commercial Insurance, strong presence in small and middle market1

Top 3 player in Personal Insurance through independent agents2

Leadership position with distribution

Consistently named top 5 carrier for both commercial and personal lines3

Industry leading data and analytics

Industry leading claim and risk control capabilities

700+ risk control consultants and specialists

~13,000 claim professionals and specialists

Claim recognized with 2014 Business Insurance Buyers Choice Award4

1. Source: SNL Financial. Based on 2015 direct written premium. Total excludes other accident & health. 2. Source: SNL Financial. Based on 2015 direct written premium. TRV data does not include TX Assumed business.3. Bi-annual Goldman Sachs Property & Casualty Pricing Survey.4. Travelers Claim received top rating for service, excellence and expertise in both Workers Compensation and Auto.

4

Travelers Business Segments

2015 Net Written Premiums: $24.1 Billion

Personal Insurance$7.4B

Bond & Specialty Insurance$2.1B

Business and International Insurance $14.6B

$22,447 $22,767 $23,904 $24,121

$12,066 $12,511

2012 2013 2014 2015 2Q YTD2015

2Q YTD2016

Net Written Premiums

5

Travelers Consolidated Overview

1Excludes catastrophe losses and net favorable prior year reserve development.

$2,441

$3,567 $3,641

$3,437

$1,633 $1,347

$2,473

$3,673 $3,692

$3,439

$1,645

$1,355

2012 2013 2014 2015 2Q YTD2015

2Q YTD2016

2012 2013 2014 2015 2Q YTD 2015 2Q YTD 2016

Underlying Combined Ratio1 93.0% 90.9% 89.9% 90.1% 90.4% 91.2%

Impact of:

Catastrophe losses 8.3 pts 2.6 pts 3.0 pts 2.1 pts 3.3 pts 5.4 pts

Net favorable prior year reserve development (4.2) pts (3.7) pts (3.9) pts (3.9) pts (3.8) pts (3.9) pts

Combined Ratio 97.1% 89.8% 89.0% 88.3% 89.9% 92.7%

($ in millions)

Operating Income Net Income

Long-term fixed net investment portfolio investment income less holding company interest expense

Non-fixed net investment portfolio investment income

Underwriting gain/(loss) and other

Short-term fixed net investment portfolio investment income

2011

Full Year

2012

6.1% 11.0%

8.0%

(2.9%)

9.0%

0.9%

0.1%

15.5%

2013

1.6%

8.1%

1.3%

9.4%

From Jan. 1, 2005 through Jun. 30, 2016, TRVs average annual operating ROE was approximately 13.4 %

15.5% 15.2%

8.5%1.3%

7.3%

7.0%

2014 2015

8.4%

7.1% 1.5%

6.9%

2015 2016

Year-to-Date

14.3%

7.5%6.8%

1.0%

6.5%

12.0%

7.4%7.8%

0.7%

6.2%

14.1%

8.3%

0.7%

4.7%

9.4%

2005 through

2010

0.4%

6

1.2% 1.5%

0.9%

6.5%

6.8%

5.2%

0.1%0.5%

Generation of Top Tier Earnings

7.5%

17.9% 18.0%

11.4%

13.5%

12.1%

5.7%

9.8%

14.6% 14.6%14.2%

11.2%11.9%

10.8%9.8%

7.9%8.3%

7.4%

6.4%6.6%

8.4%7.8% 7.6%

6.8%

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2Q 2016YTD

`

TRV return on equity

Return on Equity vs. Estimated Cost of Capital1

TRV estimated cost of capital1

1 Cost of capital: weighted average cost of capital represents the cost of equity, debt and hybrid securities proportional to the total capital of the enterprise. The cost of equity: weekly two year adjusted beta against S&P 500, Ibbotson equity market risk premium and ten-year Treasury.

From Jan. 1, 2005 through June 30, 2016, TRVs average annual ROE was approximately 12.6%

7

Generation of Top Tier Earnings

Excess capital in

operating

companies

transferred to

holding company

Operating

company capital

maintained at

levels needed to

support current

business profile

and growth

opportunities

consistent with AA

rating objective

Holding company

leverage

maintained at level

consistent with AA

rating objective

Holding company

liquidity

maintained in

excess of amount

equal to one years

dividends and

interest

Unneeded

capital

returned

to

shareholders

8

Balanced Approach to Rightsizing Capital

$1,622

$4,208

$4,601

$2,924

$3,622

$3,216

$1,426

$2,473

$3,673 $3,692

$3,439

$1,355

$622

$1,817

$3,685

$2,834

$3,990

$5,670

$3,569

$2,150

$3,134

$4,010$3,894

$1,478

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2Q 2016YTD

`

Since the initial share repurchase authorization granted by the Board on May 2, 2006, TRV has returned $36.0 billion1 in share repurchases and dividends or 119% of the market capitalization on that day

1 Through June 30, 2016.

($ in millions)

Net Income Share Repurchases & Dividends

9

38% 43% 80% 97% 110% 176% 250% 87% 85% 109% 113% 109%

Share Repurchases and Dividends as a Percentage of Net Income:

Excess Capital Returned to Shareholders

Book Value Per Share

Adjusted Book Value Per Share1

$31.94$36.86

$42.22 $43.12

$52.54$58.47

$62.32$67.31

$70.15$77.08 $79.75

$85.73

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 June 30,2016

`

$31.47$36.21

$41.25 $43.37$48.98

$54.19 $55.01$59.09

$66.41$70.98

$75.39 $77.61

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 June 30,2016

`

1 Adjusted book value per share is total common shareholders equity excluding the after-tax impact of net unrealized investment gains and losses divided by the number of common shares outstanding.

10

Consistently Growing Book Value Per Share

$0.91$1.01

$1.13$1.19 $1.23

$1.41

$1.59

$1.79

$1.96

$2.15

$2.38

$2.62

2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

`

1 Based on 1Q dividend of $0.61 and 2Q dividend of $0.67. Dividend of $0.67 assumed for 3Q and 4Q 2016.

2 As of market close on June 30, 2016.

Travelers has paid cash dividends without interruption for 145 years; current dividend yield2: 2.2%

11

Dividends Per Share

1

Consistent Dividend Growth

Return on capital focus has resulted in top tier returns in P&C industry and financial services industry broadly

Average Return on Equity: 2005 Mar. 31, 2016

12.7%

10.1% 9.7%

8.1%

7.0% 6.8%

-5.2%

S&P Property &Casualty

S&PLife & Health

S&P DiversifiedFinancials

S&PFinancials

S&PBanks

S&P Multi-lineInsurance

`

TRV Return on Equity vs. Other Financials: 2005 Mar. 31, 2016

Source: Bloomberg.

12

Return Focused Company

329%

250%

196%

174%

154%

148%

145%

139%

138%

109%

109%

88%

85%

81%

76%

70%

70%

69%

59%

58%

53%

52%

51%

43%

43%

24%

3%

3%

2%

-5%

-5%

-10%

Aetna

Cigna

Cincinnati Financial

Simon Property Group

Anthem

Allstate

Chubb

American Tower Corp.

Progressive

BlackRock

Hartford

Berkshire Hathaway

Wells Fargo

XL

U.S. Bancorp

JPMorgan Chase

Charles Schwab Corp.

American Express

PNC Financial

CNA Financial

Bank of New York Mellon

Prudential Financial

Manulife Financial

Bank of America

MetLife

Morgan Stanley

AIG

Goldman Sachs

Citigroup

175%

140%

129%

117%

110%

86%

82%

81%

81%

80%

78%

63%

61%

61%

58%

56%

56%

55%

53%

52%

49%

48%

46%

42%

42%

41%

37%

33%

22%

18%

11%

8%

Aetna

Cigna

Anthem


Hartford

Allstate


BlackRock

Progressive

Chubb


Berkshire Hathaway



AIG

JPMorgan Chase

Wells Fargo

PNC Financial


Manulife Financial

XL

Morgan Stanley

CNA Financial

U.S. Bancorp

MetLife

Goldman Sachs

Bank of America

American Express

Citigroup

53%

39%

31%

25%

24%

18%

18%

16%

9%

7%

5%

3%

2%

0%

0%

-2%

-3%

-4%

-5%

-5%

-7%

-8%

-10%

-15%

-16%

-17%

-21%

-22%

-23%

-24%

-31%

-33%


Aetna

Progressive


Cigna


Chubb

Hartford

Anthem

JPMorgan Chase

Allstate

XL

BlackRock


AIG

Berkshire Hathaway

CNA Financial

U.S. Bancorp

PNC Financial

Wells Fargo


Manulife Financial


Citigroup

Goldman Sachs

MetLife

Bank of America

Morgan Stanley

American Express

(1) Total return is a concept used to compare the performance of a company's stock over time and is the ratio of the net stock price change plus the cumulative amount of dividends over the specified time period, assuming dividend reinvestment, to the stock price at the beginning of the time period. Total return to shareholders is not included as an indication of future performance.

(2) By market capitalization as of June 30, 2016.

20 Largest S&P Financial Companies2 & Other Selected Financial Companies

Source: SNL Financial

13

TRAVELERS

S&P 500

S&P Financials

1+ Year Total ReturnJanuary 1, 2015 June 30, 2016

TRAVELERS

S&P 500

S&P Financials



TRAVELERS

S&P 500

S&P Financials

13

Total Return1

Additional InformationAdditional Information

APPENDIX

15

($ in millions)

1 Average duration of fixed maturities and short-term securities, net of securities lending activities and net receivables and

payables on investment sales and purchases.

On-going

- Investment portfolio managed to

support insurance operations

- Portfolio structured to defease

obligations to policyholders and

other creditors and to achieve

appropriate risk adjusted returns on

capital

- Disciplined, long-term risk/return

analysis drives asset allocation

decisions

Current view

- High quality

- Shorter duration

Investment Strategy

June 30, December 31, December 31,

2016 2015 2014

Total Investments 72,470$ 70,470$ 73,261$

Taxable fixed maturities 41% 42% 41%

Tax-exempt fixed maturities 46% 44% 46%

Total fixed maturities 87% 86% 87%

Equity securities 1% 1% 1%

Real estate investments 1% 1% 1%

Short-term securities 6% 7% 6%

Total fixed income 95% 95% 95%

Private equity funds 3% 3% 3%

Hedge funds - % 1% - %

Real estate partnerships 1% 1% 1%

Other investments 1% - % 1%

Total non-fixed income 5% 5% 5%

100% 100% 100%

Fixed maturities data:

Average quality rating Aa2, AA Aa2, AA Aa2, AA

Below investment grade 2.8% 2.8% 3.0%

Average duration1 3.9 3.9 3.5

Consistent High Quality Investment Portfolio

1 Corresponding pre-tax amounts are: 2014, $697; 2015, $595; 1Q15, $592; 2Q15, $632; 3Q15, $614; 4Q15, $541; 1Q16, $544, 2Q16, $5492 2014 and 2015 data represent quarterly average3 Excludes investment expenses

Total 2.8% 2.6% 2.7% 2.7% 2.6% 2.6% 2.5% 2.5%

Short-term 0.1% 0.2% 0.1% 0.2% 0.2% 0.2% 0.3% 0.4%

Long-term 2.9% 2.8% 2.8% 2.8% 2.8% 2.8% 2.7% 2.7%

7.4% 4.1% 3.6% 5.8% 5.0% 1.8% 2.5% 2.9%

$462 $428 $436 $431 $422 $422 $410

2014 2015 1Q'15 2Q'15 3Q'15 4Q'15 1Q'16 2Q'16

`

2

$98

$55$48

$79$68

$25 $33

2014 2015 1Q'15 2Q'15 3Q'15 4Q'15 1Q'16 2Q'1622

$554

$476 $478$503 $484

$440 $439

2014 2015 1Q'15 2Q'15 3Q'15 4Q'15 1Q'16 2Q'16

After-tax yieldLong-term Short-term

After-tax yield

2

3.1% 2.7% 2.7% 2.9% 2.7% 2.5% 2.5% 2.5%

Total 1

Fixed Income 3 Non-Fixed Income 3

After-tax yield

22

$442

$412

$38

($ in millions)

Combined Net Investment Income - After-tax

16


Business and International Insurance

Middle Market

43%

Select Accounts

19%

First Party11%

Specialized Distribution8%

National Accounts

7%

International12%

GeneralLiability

13%

International and Other

13%Workers

Compensation27%

Commercial Automobile

13%

CommercialMulti-Peril

22%

By Market By Product Line

Domestic Predominantly small and

middle market insurer #1 writer in workers

compensation with industry leading profitability1

Top 5 writer in property; consistently outperform industry profitability1

International Top 10 Canadian writer;

strong presence with agents and brokers

Joint venture with J. Malucelli, the market leader in Brazil Surety

17

Commercial Property

12%

1. Market share ranking source: SNL Financial. Based on 2015 direct written premium.

$12,929 $13,512

$14,636 $14,583

$7,476 $7,594

2012 2013 2014 2015 2Q YTD2015

2Q YTD2016

Net Written Premiums

18

Operating Income

$1,981

$2,404 $2,347

$2,170

$1,058

$869

2012 2013 2014 2015 2Q YTD2015

2Q YTD2016

($ in millions)


Business and International Insurance

2012 2013 2014 20152Q YTD

20152Q YTD

2016


Impact of:



Combined Ratio 97.1% 92.8% 93.1% 92.1% 93.3% 96.2%

19

Bond & Specialty Insurance


Management Liability64%

Surety36%

Surety Largest writer of Surety in US1

Industry leading profitability

Management Liability Diversified risk profile Strong presence in small and

middle market

1. Market share ranking source: SNL Financial. Based on 2015 direct written premium.

$1,924 $2,030

$2,103 $2,081

$1,012 $1,028

2012 2013 2014 2015 2Q YTD2015

2Q YTD2016

20

Bond & Specialty Insurance

Net Written Premiums Operating Income

$504

$573

$727

$633

$275

$346

2012 2013 2014 2015 2Q YTD2015

2Q YTD2016

($ in millions)


2012 2013 2014 20152Q YTD

20152Q YTD 2016


Impact of:



Combined Ratio 78.4% 73.4% 60.8% 67.9% 74.9% 60.8%

21

Personal Insurance


Automobile50%

Homeowners & Other50%

Personal Insurance Premier company within

independent agent channel Full account solution

provider with industry leading property results and strong position in the preferred market

Competing successfully in a changing environment (Quantum 2.0)

22

Net Written Premiums Operating Income

$7,594 $7,225 $7,165

$7,457

$3,578 $3,889

2012 2013 2014 2015 2Q YTD2015

2Q YTD2016

$217

$838 $824 $889

$426

$255

2012 2013 2014 2015 2Q YTD2015

2Q YTD2016

($ in millions)


Personal Insurance

2012 2013 2014 20152Q YTD

20152Q YTD

2016


Impact of:



Combined Ratio 101.9% 88.9% 88.7% 86.6% 87.3% 94.7%

2323

This presentation contains, and management may make, certain forward-looking statements within the meaning of the Private Securities Litigation Reform Act of 1995. All

statements, other than statements of historical facts, may be forward-looking statements. Words such as may, will, should, likely, anticipates, expects, intends,

plans, projects, believes, estimates and similar expressions are used to identify these forward-looking statements. These statements include, among other things, our

outlook, our future results of operations and financial condition (including anticipated premium volume, premium rates, margins, net and operating income, investment

income and performance, loss costs, return on equity and expected current returns and combined ratios), our share repurchase plans, future pension plan contributions,

the sufficiency of our reserves, the impact of emerging claims issues and litigation, the cost and availability of reinsurance coverage, catastrophe losses, the impact of

investment, economic and underwriting market conditions and our strategic initiatives.

We caution investors that such statements are subject to risks and uncertainties, many of which are difficult to predict and generally beyond the Companys control, that

could cause actual results to differ materially from those expressed in, or implied or projected by, the forward-looking information and statements. Some of the factors that

could cause actual results to differ include, but are not limited to, the following:

Catastrophe losses;

Financial market disruption, economic downturn or prolonged period of slow economic growth;

Changes to our claims and claim adjustment expense reserves;

The performance of our investment portfolio;

Asbestos and environmental claims and related litigation;

Mass tort claims;

Emerging claim and coverage issues;

Competition, including the impact of competition on our business volume and profitability;

Disruptions to our relationships with our independent agents and brokers;

The collectability and availability of reinsurance coverage;

Credit risk we face in certain of our business and investment operations, including through the utilization of reinsurance or structured settlements, as well as guarantees or

indemnifications from third parties;

The federal, state and international regulatory environment;

A downgrade in our claims-paying or financial strength ratings;

The inability of our insurance subsidiaries to pay dividends to our holding company in sufficient amounts;

Risks associated with developing new products or expanding in targeted markets;

Risks associated with our use of pricing and capital models;

Limits to the effectiveness of our information technology systems;

Difficulties with our technology, data and network security, including as a result of cyber-attacks, outsourcing relationships, or cloud-based technology;

Risks associated with our business outside of the United States, including foreign currency exchange fluctuations and restrictive regulations, as well as the risks and

uncertainties associated with the United Kingdoms expected withdrawal from the European Union;

Loss of or significant restrictions on the use of particular types of underwriting criteria, such as credit scoring, or other data or methodologies, in the pricing and

underwriting of insurance products;

Risks associated with acquisitions and integration of acquired businesses;

Limits to the effectiveness of our compliance controls;

Our ability to hire and retain qualified employees;

We may be unable to protect and enforce our own intellectual property or may be subject to claims for infringing the intellectual property of others;

Changes to existing accounting standards;

Changes in tax laws that adversely impact our investment portfolio or operating results; and

Factors impacting the operation of our share repurchase plans

For a more detailed discussion of these factors, see the information under "Risk Factors" and Managements Discussion and Analysis of Financial Condition and Results

of Operations in our most recent Form 10-K, as updated by our periodic filings with the Securities and Exchange Commission (SEC), which are accessible on the SECs

website (www.sec.gov). Our forward-looking statements speak only as of the date of this presentation or as of the date they are made, and we undertake no obligation to

update those statements.

Explanatory Note

24

Disclosure

In this presentation, we may refer to some non-GAAP financial measures. For a reconciliation of these

measures to the most comparable GAAP measures and a glossary of financial measures, we refer you

to the press release and financial supplement that we have made available in connection with this

presentation and our most recent annual report on Form 10-K filed with the Securities and Exchange

Commission (SEC). See the For Investors section at Travelers.com.

For further information, please see Travelers reports filed with the SEC pursuant to the Securities

Exchange Act of 1934 which are available at the SECs website (www.sec.gov).

Copies of this presentation and the accompanying webcast are publicly available on the Travelers

website (www.travelers.com). This presentation should be read with the accompanying webcast and

related press release and financial supplement.

From time to time, Travelers may use its website and/or social media outlets, such as Facebook and

Twitter, as distribution channels of material company information. Financial and other important

information regarding the company is routinely accessible through and posted on our website at

http://investor.travelers.com, our Facebook page at https://www.facebook.com/travelers and our Twitter

account (@Travelers) at https://twitter.com/travelers. In addition, you may automatically receive email

alerts and other information about Travelers when you enroll your email address by visiting the Email

Notification section at http://investor.travelers.com.

travelers.comhttp://www.sec.gov/http://investor.travelers.com/https://www.facebook.com/travelershttps://twitter.com/travelershttp://investor.travelers.com/

2525

Glossary of Financial Measures and Reconciliations of Non-GAAP Measures

to GAAP Measures

The following measures are used by the Companys management to evaluate financial performance against historical results and establish targets on a

consolidated basis. In some cases, these measures are considered non-GAAP financial measures under applicable SEC rules because they are not displayed as

separate line items in the consolidated financial statements or are not required to be disclosed in the notes to financial statements or, in some cases, include or

exclude certain items not ordinarily included or excluded in the most comparable GAAP financial measure. Reconciliations of non-GAAP measures to their most

directly comparable GAAP measures also follow.

In the opinion of the Companys management, a discussion of these measures provides investors, financial analysts, rating agencies and other financial statement

users with a better understanding of the significant factors that comprise the Companys periodic results of operations and how management evaluates the

Companys financial performance. Internally, the Companys management uses these measures to evaluate performance against historical results, to establish

financial targets on a consolidated basis and for other reasons, which are discussed below.

Some of these measures exclude net realized investment gains (losses), net of tax, and/or net unrealized investment gains (losses), net of tax, which can be

significantly impacted by both discretionary and other economic factors and are not necessarily indicative of operating trends.

Other companies may calculate these measures differently, and, therefore, their measures may not be comparable to those used by the Companys management.

RECONCILIATION OF OPERATING INCOME AND CERTAIN OTHER NON-GAAP MEASURES TO NET INCOME

Operating income is net income excluding the after-tax impact of net realized investment gains (losses) and discontinued operations. Management uses operating

income to analyze each segments performance and as a tool in making business decisions. Financial statement users also consider operating income when

analyzing the results and trends of insurance companies.

Reconciliation of Operating Income less Preferred Dividends to Net Income

($ in millions, after-tax) 2015 2014 2013 2012 2011 2010 2009 2008 2007 2006 2005

Operating income, less preferred dividends 3,437$ 3,641$ 3,567$ 2,441$ 1,389$ 3,040$ 3,597$ 3,191$ 4,496$ 4,195$ 2,020$

Preferred dividends - - - - 1 3 3 4 4 5 6

Operating income 3,437 3,641 3,567 2,441 1,390 3,043 3,600 3,195 4,500 4,200 2,026

Net realized investment gains/(losses) 2 51 106 32 36 173 22 (271) 101 8 35

Income from continuing operations 3,439 3,692 3,673 2,473 1,426 3,216 3,622 2,924 4,601 4,208 2,061

Discontinued operations - - - - - - - - - - (439)

Net income 3,439$ 3,692$ 3,673$ 2,473$ 1,426$ 3,216$ 3,622$ 2,924$ 4,601$ 4,208$ 1,622$

Twelve Months Ended December 31,

Three Months Ended Six Months Ended

June 30, June 30,

($ in millions, after-tax) 2016 2015 2016 2015

Operating income 649$ 806$ 1,347$ 1,633$

Net realized investment gains 15 6 8 12

Net income 664$ 812$ 1,355$ 1,645$

2626

Reconciliation of Operating Income by Segment to Total Operating Income


to GAAP Measures


Business and International Insurance 2,170$ 2,347$ 2,404$ 1,981$

Bond & Specialty Insurance 633 727 573 504

Personal Insurance 889 824 838 217

Total segment operating income 3,692 3,898 3,815 2,702

Interest Expense and Other (255) (257) (248) (261)

Total operating income 3,437$ 3,641$ 3,567$ 2,441$

Twelve months ended December 31,


June 30, June 30,


Business and International Insurance 393$ 543$ 869$ 1,058$

Bond & Specialty Insurance 202 151 346 275

Personal Insurance 116 174 255 426

Total segment operating income 711 868 1,470 1,759

Interest Expense and Other (62) (62) (123) (126)

Total operating income 649$ 806$ 1,347$ 1,633$

2727


to GAAP MeasuresRECONCILIATION OF ADJUSTED SHAREHOLDERS EQUITY TO SHAREHOLDERS EQUITY AND OPERATING RETURN ON EQUITY TO RETURN ON

EQUITY

Adjusted shareholders equity is shareholders equity excluding net unrealized investment gains (losses), net of tax, net realized investment gains (losses), net

of tax, for the period presented, preferred stock and discontinued operations.

Reconciliation of Adjusted Shareholders Equity to Shareholders Equity

Return on equity is the ratio of annualized net income less preferred dividends to average shareholders equity for the periods presented. Operating return on

equity is the ratio of annualized operating income less preferred dividends to adjusted average shareholders equity for the periods presented. In the opinion of the

Companys management, these are important indicators of how well management creates value for its shareholders through its operating activities and its capital

management.

Average shareholders equity is (a) the sum of total shareholders equity excluding preferred stock at the beginning and end of each of the quarters for the period

presented divided by (b) the number of quarters in the period presented times two. Adjusted average shareholders equity is (a) the sum of adjusted

shareholders equity at the beginning and end of each of the quarters for the period presented divided by (b) the number of quarters in the period presented times

two.

Calculation of Operating Return on Equity and Return on Equity

As of December 31,

($ in millions) 2015 2014 2013 2012 2011 2010 2009 2008 2007 2006 2005

Adjusted shareholders' equity $ 22,307 $ 22,819 $ 23,368 $ 22,270 $ 21,570 $ 23,375 $ 25,458 $ 25,647 $ 25,783 $ 24,545 $ 22,227

Net unrealized investment gains /(losses), net of tax 1,289 1,966 1,322 3,103 2,871 1,859 1,856 (146) 620 453 327

Net realized investment gains /(losses), net of tax 2 51 106 32 36 173 22 (271) 101 8 35

Preferred stock - - - - - 68 79 89 112 129 153

Discontinued operations - - - - - - - - - - (439)

Shareholders' equity $ 23,598 $ 24,836 $ 24,796 $ 25,405 $ 24,477 $ 25,475 $ 27,415 $ 25,319 $ 26,616 $ 25,135 $ 22,303


June 30, June 30,


Annualized operating income 2,598$ 3,225$ 2,695$ 3,266$

Adjusted average shareholders' equity 22,383 22,755 22,372 22,786

Operating return on equity 11.6% 14.2% 12.0% 14.3%

Annualized net income 2,654$ 3,247$ 2,710$ 3,289$

Average shareholders' equity 24,440 24,484 24,161 24,662

Return on equity 10.9% 13.3% 11.2% 13.3%

Six Months Ended

June 30,

($ in millions) 2016 2015 2015 2014 2013 2012 2011 2010 2009 2008 2007 2006 2005

Operating income, less preferred dividends 1,347$ 1,633$ 3,437$ 3,641$ 3,567$ 2,441$ 1,389$ 3,040$ 3,597$ 3,191$ 4,496$ 4,195$ 2,020$

Annualized operating income 2,695 3,266

Adjusted average shareholders' equity 22,372 22,786 22,681 23,447 23,004 22,158 22,806 24,285 25,777 25,668 25,350 23,381 21,118

Operating return on equity 12.0% 14.3% 15.2% 15.5% 15.5% 11.0% 6.1% 12.5% 14.0% 12.4% 17.7% 17.9% 9.6%

Average annual operating return on equity

for the period Jan. 1, 2005 through June 30, 201613.4%

Twelve Months Ended December 31,

Average annual operating return on equity over a period is the ratio of:

a) the sum of operating income less preferred dividends for the periods presented to

b) the sum of: 1) the sum of the adjusted average shareholders equity for all full years in the period presented, and 2) for partial years in the period

presented, the number of quarters in that partial year divided by four, multiplied by the adjusted average shareholders equi ty of the partial year.

Calculation of Average Annual Operating Return on Equity from January 1, 2005 through June 30, 2016

COMBINED RATIO AND ADJUSTMENTS FOR UNDERLYING COMBINED RATIO

Combined ratio: For Statutory Accounting Practices (SAP), the combined ratio is the sum of the SAP loss and LAE ratio and the SAP underwriting

expense ratio as defined in the statutory financial statements required by insurance regulators. The combined ratio as used in this presentation is the

equivalent of, and is calculated in the same manner as, the SAP combined ratio except that the SAP underwriting expense ratio is based on net written

premium and the underwriting expense ratio as used in this earnings release is based on net earned premiums.

For SAP, the loss and LAE ratio is the ratio of incurred losses and loss adjustment expenses less certain administrative services fee income to net

earned premiums as defined in the statutory financial statements required by insurance regulators. The loss and LAE ratio as used in this presentation

is calculated in the same manner as the SAP ratio.

For SAP, the underwriting expense ratio is the ratio of underwriting expenses incurred (including commissions paid), less certain administrative services

fee income and billing and policy fees, to net written premiums as defined in the statutory financial statements required by insurance regulators. The

underwriting expense ratio as used in this presentation, is the ratio of underwriting expenses (including the amortization of deferred acquisition costs),

less certain administrative services fee income, billing and policy fees and other, to net earned premiums.

The combined ratio, loss and LAE ratio, and underwriting expense ratio are used as indicators of the Companys underwriting d iscipline, efficiency in

acquiring and servicing its business and overall underwriting profitability. A combined ratio under 100% generally indicates an underwriting profit. A

combined ratio over 100% generally indicates an underwriting loss.

Other companies method of computing similarly titled measures may not be comparable to the Companys method of computing these ratios.

Underlying combined ratio represents the combined ratio excluding the impact of net prior year reserve development and catastrophes. The

underlying combined ratio is an indicator of the Companys underwriting discipline and underwriting profitability for the current accident year. 2828


to GAAP Measures

2929


to GAAP MeasuresRECONCILIATION OF CERTAIN NON-GAAP MEASURES TO BOOK VALUE PER SHARE AND SHAREHOLDERS EQUITY

Book value per share is total common shareholders equity divided by the number of common shares outstanding. Adjusted book value per share is total

common shareholders equity excluding the after-tax impact of net unrealized investment gains and losses, divided by the number of common shares outstanding.

In the opinion of the Companys management, adjusted book value per share is useful in an analysis of a property casualty companys book value per share as it

removes the effect of changing prices on invested assets (i.e., net unrealized investment gains (losses), net of tax), which do not have an equivalent impact on

unpaid claims and claim adjustment expense reserves.

Reconciliation of Common Shareholders Equity, excluding net unrealized investment gains/(losses), net of tax, to Shareholders Equity

OTHER DEFINITIONS

Gross written premiums reflect the direct and assumed contractually determined amounts charged to policyholders for the effective period of the contract based

on the terms and conditions of the insurance contract. Net written premiums reflect gross written premiums less premiums ceded to reinsurers.

For a glossary of other financial terms used in this presentation, we refer you to the Companys most recent annual report on Form 10-K filed with the SEC.

($ in millions) 2015 1 2014 1 2Q 2016 1Q 2016 4Q 2015 3Q 2015 2Q 2015 1Q 2015 4Q 2014 3Q 2014 2Q 2014

Pre-tax net investment income 595$ 697$ 549$ 544$ 541$ 614$ 632$ 592$ 637$ 719$ 695$

Net investment income tax expense 119 143 107 105 101 130 129 114 124 151 142

After-tax net investment income 476$ 554$ 442$ 439$ 440$ 484$ 503$ 478$ 513$ 568$ 553$

Reconciliation of Pre-tax Net Investment Income to After-tax Net Investment Income

12014 and 2015 data represent quarterly average

As of June 30,

($ in millions, except per share amounts) 2016 2015 2014 2013 2012 2011 2010 2009 2008 2007 2006 2005

C o mmo n shareho lders' equity, excluding net

unrealized investment gains/ ( lo sses) , net o f tax$22,373 $22,309 $22,870 $23,474 $22,302 $21,606 $23,548 $25,480 $25,376 $25,884 $24,553 $21,823

Net unrealized investment gains/(losses), net of tax 2,341 1,289 1,966 1,322 3,103 2,871 1,859 1,856 (146) 620 453 327

Preferred stock - - - - - - 68 79 89 112 129 153

Shareho lders' equity $24,714 $23,598 $24,836 $24,796 $25,405 $24,477 $25,475 $27,415 $25,319 $26,616 $25,135 $22,303

C o mmo n shares o utstanding 288.3 295.9 322.2 353.5 377.4 392.8 434.6 520.3 585.1 627.8 678.3 693.4

Adjusted book value per share $77.61 $75.39 $70.98 $66.41 $59.09 $55.01 $54.19 $48.98 $43.37 $41.25 $36.21 $31.47

Book value per share 85.73 79.75 77.08 70.15 67.31 62.32 58.47 52.54 43.12 42.22 36.86 31.94

As of December 31,

Additional InformationAdditional Information

The Travelers Companies, Inc.

Code of BusinessConduct and EthicsJUNE 2016

H O N E S T Y. I N T E G R I T Y. A C C O U N TA B I L I T Y.

A M E S S A G E F R O M A L A N S C H N I T Z E R

T A B L E O F C O N T E N T S P A G E u2 Code of Conduct

As Chief Executive Officer, Im proud of our Companys reputation for honesty,

integrity, and accountability. Its a reputation weve worked hard to build.

The Code of Business Conduct and Ethics is an important tool for helping us manage

our business. Of course, no code of conduct can anticipate all ethical situations

that may confront you. When youre unsure of which decision is the right one, its

important that you know there is guidance available. Within our organization, we have

many Legal, Compliance, and Human Resources personnel who are trained to help

you reach the right decision, regardless of the circumstances. We also have our Ethics

Helpline, which can be accessed 24/7.

Please remember, employees who get results at the cost of legal violations, through

dishonest dealings or other unethical behavior, do more than just violate our

standards. They undercut our ability to create shareholder value and serve our

stakeholders by undermining our reputation.

Please dont allow anything to compromise your commitment to integrity.

In closing, I ask each of you to join me in upholding the principles in our Code of Business

Conduct and Ethics.

Thank you.

Honesty. Integrity. Accountability.

Its better under the umbrella


TA B L E O F C O N T E N T S

P A G E4 Code of Conduct

5 . . . . . . . . . . . . . . . . . .u Introduction

6 . . . . . . . . . . . . . . . . . .u Compliance with Laws, Rules and Regulations/Cooperation

6 . . . . . . . . . . . . . . . . . .u Reporting Concerns and Non-Retaliation

8 . . . . . . . . . . . . . . . . . .u Certification

8 . . . . . . . . . . . . . . . . . .u Conflicts of Interest

11 . . . . . . . . . . . . . . . . . .u Anti-Bribery and Anti-Corruption

12 . . . . . . . . . . . . . . . . . .u Antitrust, Competition and Fair Dealing

13 . . . . . . . . . . . . . . . . . .u Buying or Selling Securities

13 . . . . . . . . . . . . . . . . . .u Accuracy of Company Records and Finance-Related Reporting

14 . . . . . . . . . . . . . . . . . . u Privacy and Information

15 . . . . . . . . . . . . . . . . . .u Protection and Proper Use of Corporate Assets

16 . . . . . . . . . . . . . . . . . .u Disclosure of Crimes and Penalties

16 . . . . . . . . . . . . . . . . . .u Diversity and Fair Employment Practices

16 . . . . . . . . . . . . . . . . . .u Claim Handling

16 . . . . . . . . . . . . . . . . . .u Policies

17 . . . . . . . . . . . . . . . . . .u Violations

17 . . . . . . . . . . . . . . . . . .u Exceptions and Authority

19 . . . . . . . . . . . . . . . . . .u AppendixEthics Helpline

Enterprise ResourcesContact ListBrazilCanadaEurope

I N T R O D U C T I O N

The Travelers Companies, Inc. and its subsidiaries (Travelers or the Company) expect all employees, officers and directors to act in accordance with the highest standards of personal and professional integrity and ethics in their work for the Company. Although Travelers operates in countries across the globe and local laws, regulations and customs vary, Travelers commitment to conducting business according to the highest standards of ethical conduct transcends jurisdictional boundaries. This Code of Business Conduct and Ethics (Code of Conduct) provides principles for each of us to follow in the performance of our activities on behalf of Travelers. While no code can ever address every circumstance that might arise, this Code of Conduct provides a framework for sound ethical business decisions. It also constitutes our code of ethics under applicable rules of the Securities and Exchange Commission and The New York Stock Exchange.

The principles in this Code of Conduct are further supported and reinforced for employees, officers and directors by various Company policies and standards of conduct. These various policies and standards of conduct are separate from this Code of Conduct. Most of them can be accessed electronically through the Policies and Standards site available on each countrys inside page or through other means.

This Code of Conduct is not a contract of employment and does not convey employment rights or guarantee employment for any period of time.

The Code of Conduct applies to all employees, officers and directors of Travelers, and provides principles for each of us to follow in the performance of our activities on behalf of Travelers.

By adhering to this Code of Conduct and applicable laws, regulations and Company policies, you can help to ensure the long-term success of our organization.

The principles in this Code of Conduct are further supported and reinforced for employees, officers and directors by various Company policies and standards of conduct.


Reporting Concerns and Non-RetaliationYou are expected to immediately report known or suspected violations of this Code of Conduct, Travelers policies or applicable laws and regulations.

Raising Ethical Concerns/Reporting Obligations

If you are aware of, or suspect, conduct that is unlawful or violates this Code of Conduct or Travelers policies, you are expected to immediately notify a member of senior management, Human Resources, the Chief Compliance Officer or Group General Counsel for your business area or location, or the enterprise Chief Ethics and Compliance Officer. Concerns about the Companys financial statements, accounting, internal controls, auditing matters and public disclosures are expected to be immediately reported as well. (See the Accuracy of Company Records and Finance-Related Reporting section below.) Early identification and resolution of these issues is critical to maintaining Travelers strong relationships with its shareholders, regulators, customers, business partners and employees.

If you have questions or concerns related to your responsibilities with respect to this Code of Conduct or are unsure about the proper course of action in a particular situation, you should seek guidance from management, Human Resources, compliance personnel or Travelers internal legal counsel.

CONTACT US u

If you are aware of, or suspect, conduct that is unlawful or violates this Code of Conduct or Travelers policies, notify a member of senior management, Human Resources, the Chief Compliance Officer or Group General Counsel for your business area or location, or the enterprise Chief Ethics and Compliance Officer.

Compliance with Laws, Rules and Regulations/CooperationIt is the Companys policy to comply with all applicable laws, rules and regulations.

It is the Companys policy to comply with all applicable laws, rules and regulations. It is the personal responsibility of each employee, officer and director to adhere to the requirements imposed by the laws, rules and regulations in every jurisdiction where the Company operates.

If there appears to be a conflict between this Code of Conduct and local laws, or if you have questions about interpretation of applicable laws, you should consult with your internal Travelers legal counsel. Generally, when there is a difference between this Code of Conduct and other policies that may apply to you, or between this Code of Conduct and the laws of the jurisdictions in which you conduct business, the more restrictive requirement will govern.

Where required by law or as directed by the Company, all employees, officers and directors are expected to cooperate with all Company, governmental and regulatory investigations. You should never take any action to improperly influence, coerce, manipulate or mislead the Company or any governmental or regulatory representative, or withhold relevant information from any of them. You are also expected to report to the Company any improper, coercive, manipulative or misleading actions by others during the course of any investigation by the Company or any governmental or regulatory body.

Notify


If you request when reporting a violation, everyeffort will be made to protect your identity; however, it maybe impossible to keep your identity because of the demands of conducting a thorough investigation or because of legal requirements.

In addition, employees may ask questions, raise concerns and report existing or suspected non-compliance with applicable laws and regulations, this Code of Conduct or Travelers policies by filing a report through the Ethics Helpline. The Ethics Helplineis a telephone and web-based reporting system operated by an independent third party and is available 24/7. Employee reports to the Ethics Helpline may be made anonymously, and may be made in the local languages of the various jurisdictions in which we operate.

Nothing contained in this Code of Conduct or any other Travelers policy or agreement, is intended to prohibit or restrict employees from (i) filing a complaint with, making disclosuresto, communicating with or participating in an investigation or proceeding conducted by any governmental agency (including the United States Equal Employment Opportunity Commission and the Securities and Exchange Commission); (ii) pursuing legal rights related to their employment with the Company: or (iii)engaging in activities protected by applicable laws or regulations. Notwithstanding, Travelers does not authorize the waiver of, or disclosure of information covered by, the attorney-client privilege or attorney work product doctrine or any other privilege or protection belonging to Travelers.

Contacting Travelers Ethics and Compliance Office

You may contact Travelers enterprise Ethics and Compliance Office, located in the United States, by:

Calling the enterprise Chief Ethics and Compliance Officer, Christine Kalla, directly at 860.277.1231

Calling Travelers Ethics Helpline (a toll-free number available 24/7 in multiple languages) at:

866.782.1441, if in the United States See the Appendix or your countrys inside page, if outside the United States

Emailing [email protected]

Submitting a report to the Ethics Helpline website at travelers.ethicspoint.com

Mailing Chief Ethics and Compliance Officer Travelers 385 Washington Street Saint Paul, MN 55102-1396 U.S.A.

Faxing 877.307.6082

Non-Retaliation

The Company is committed to fostering an ethical, productive and respectful work environment where employees feel comfortable raising concerns. The Company strictly prohibits retaliation or harassment of any form in response to reports

E T H I C S H E L P L I N E u

Employees may ask questions, raise concerns and report existing or suspected non-compliance with applicable laws and regulations, this Code of Conduct or Travelers policies by filing a report through the Ethics Helpline. Report


made or concerns raised in good faith. Good faith does not mean that the report or concern raised must be correct, but it does require that individuals making reports or raising concerns believe that they are providing truthful information.

Additional Responsibilities for Managers

Managers are expected to demonstrate the highest ethical standards and promote the Companys commitment to compliance. Specifically, the Company expects its managers to:

Lead by example by conducting business according to the highest ethical standards.

Respond to questions their employees may have regarding responsibilities under this Code of Conduct and other Travelers policies.

Create a work environment where employees feel comfortable raising concerns by encouraging open communications, building trust, resolving issues promptly and upholding Travelers policy against retaliation.

If an employee notifies you of potential or known violations of applicable laws and regulations, this Code of Conduct or Travelers policies, you are, in turn, expected to notify a member of senior management, Human Resources, the Chief Compliance Officer or Group General Counsel for your business area or location, or the enterprise Chief Ethics and Compliance Officer.

CertificationAll employees, officers and directors are required to certify annually that they (1) understand and agree to comply with the Code of Conduct; (2) understand the various reporting channels through which concerns may be raised at Travelers, including the Ethics Helpline; (3) understand that they are expected to report any existing or potential violation of applicable laws and regulations, the Code of Conduct or Travelers policies; and (4) have not violated any provisions of the Code of Conduct.

In addition, employees and officers are required as a condition of continued employment to separately certify annually as to their compliance with other Company policies, and may be required as a condition of continued employment to complete training programs and certifications related to the Code of Conduct and other Company policies.

Certification to the Code of Conduct signifies, among other things, that you understand and agree to comply with the Code of Conduct.

Conflicts of InterestA conflict of interest occurs when an individuals private interests interfere or even appear to interfere with the interests of the Company.

A conflict of interest occurs when an individuals private interests interfere or even appear to interfere with the interests of the Company. All employees, officers and directors are expected to avoid any situation that involves a conflict of interest between personal and professional relationships. For example, a conflict of interest may arise as a result of outside activities, certain financial investments or when you or members of your family receive, or anyone on your behalf receives, improper personal benefits as a result of a business relationship with Travelers. You have an ongoing

ETHICS HELPLINE u

You have an ongoing obligation to disclose an actual or potential conflict of interest at the time it arises and have an ongoing duty to supplement disclosures as circumstances dictate.

Disclose


obligation to disclose an actual or potential conflict of interest at the time it arises and have an ongoing duty to supplement disclosures as circumstances dictate

A. Outside Activities

An outside activity, whether for profit or not for profit, by employees and officers of Travelers may be prohibited if the outside activity conflicts with the interests of the Company. Employees and officers may not accept or hold any outside position working for or providing goods or services to any competitor, business partner or customer of the Company, or to the Company itself, without the authorization of the enterprise Chief Ethics and Compliance Officer or his/her designee. This includes self-employment.

If you are engaged in an activity outside the Company, you should adhere to the following guidelines unless otherwise authorized by the enterprise Chief Ethics and Compliance Officer or his/her designee:

You should not perform work related to the outside activity during Company work hours or use Company information or resources for your outside activity, except as permitted by Company policy. For example, you should not make or receive telephone calls, or send or receive email, related to your outside activity during your Company work hours unless such activities constitute occasional inconsequential personal use.

You should not attempt to promote or sell products or services from any outside employment to your Travelers co-workers or to the Company itself.

You should not perform work that may adversely affect your judgment, objectivity or conduct in your work for Travelers.

In the context of your outside activity, you should not suggest or imply that you represent Travelers, including, without limitation, using your Travelers email or contact information.

B. Financial Investments

The Company respects the right of its employees, officers and directors to manage their investments and does not wish to interfere with their personal financial opportunities. At the same time, if you have or a family member has a substantial personal financial interest in a competitor or business partner of the Company, such a financial interest may raise conflict issues, depending on your position at Travelers, your influence on purchasing decisions, the amount of the investment, and the importance of the business relative to Travelers or the other entity. You should consult with the enterprise Chief Ethics and Compliance Officer in the event that you have questions concerning the application of this provision.

C. Receipt of Gifts (Including Meals and Entertainment)

In your capacity as an employee, officer or director, you may accept a non-cash gift, including a meal or entertainment, that:

(1) is reasonable in value,

(2) is a part of the normal business process,

(3) is lawful,

(4) is given or accepted infrequently,

(5) cannot be construed as a bribe or payoff, or as an attempt to influence you, and

(6) reflects good taste and judgment.

For purposes of this Code of Conduct, gifts include tangible objects, prizes from drawings, entertainment (e.g., sporting or other tickets and golf or other recreational activities), meals, refreshments, transportation, lodging, charitable contributions made on your behalf, or any other items, regardless of value.

Except with the authorization of the enterprise Chief Ethics and Compliance Officer or his/her designee, you should not accept gifts that do not meet these standards and you may never accept gifts of cash, gift cards, gift certificates, securities or other cash equivalents given to you in your capacity as an employee, officer or director. Gifts or other honoraria received for speaking at events are also subject to these rules.

Additionally, without the authorization of the enterprise Chief Ethics and Compliance Officer or his/her designee, you may not request, and may not allow an immediate family member or anyone on your behalf to request, gifts or preferential services or treatment from anyone engaged in or seeking a business relationship with Travelers.

Further clarification as to whether a particular gift meets the above guidelines may be addressed to the enterprise Chief Ethics and Compliance Officer directly or via the Ethics Helpline. The enterprise Chief Ethics and Compliance Officer or his/her designee may authorize acceptance of a gift outside of these guidelines that is then given to charity to avoid embarrassing a customer or business associate so long as it is clear that the gift was not given to influence you in your role with the Company or for any other improper purpose.

Individual business units and jurisdictions may have more restrictive policies with respect to the acceptance of gifts. Employees are expected to become familiar with those policies as well.

D. Giving of Gifts (Including Meals and Entertainment)

The Companys policy governing the giving of gifts (as defined in the preceding section, and including Travelers logo items, such as umbrellas) varies based on the identity of the recipient.

Appropriate gifts may be offered to customers and others seeking a business relationship with Travelers by employees authorized to do so and consistent with the limitations set forth below and business unit and expense reimbursement policies. Generally, the same rules


that apply to the receipt of gifts also apply to the giving of gifts to non-government officials and employees. You may give a gift that:

(1) is reasonable in value,

(2) is part of the normal business process,

(3) is lawful,

(4) is given or accepted infrequently,

(5) cannot be construed as a bribe or payoff, or as an attempt to influence the recipient of the gift, and

(6) reflects good taste and judgment.

However, the ability to provide gifts to government officials is strictly limited by Travelers policies and the law. Many countries, including the United States (and its states and local jurisdictions), have laws restricting and, in some cases prohibiting, gifts that may be provided to government officials and employees. The provision of gifts and other things of value, regardless of monetary value, to government officials (federal, state, provincial or local) is strictly prohibited unless specifically permitted by a Travelers policy or pre-approved in writing by the enterprise Chief Ethics and Compliance Officer or his/her designee. Government officials is a broadly defined concept and includes, without limitation, any person employed by or representing a government (or department, agency or instrumentality of a government or a government board or commission), insurance and other regulators, officials of political parties, candidates for government offices and officials of public international organizations.

In certain circumstances, the giving of gifts of even a nominal value may present a potential conflict of interest or, in extreme

cases, may constitute bribery, and must be avoided. (See the Anti-Bribery and Anti-Corruption section below.)

Individual business units and jurisdictions may have more restrictive policies with respect to the giving of gifts. Employees are expected to become familiar with those policies as well.

E. Personal Relationships

As an employee, officer or director of Travelers, you may not use your position or influence to impact a business decision that places Travelers interest secondary to your own personal interests or those of a relative or someone with whom you have a close personal relationship. This includes exercising control over personnel decisions, claim outcomes, underwriting decisions or the selection or management of a vendor, in any case in which you have an interest, without the authorization of the enterprise Chief Ethics and Compliance Officer or his/her designee.

F. Charitable Requests

You may not contact Travelers vendors or customers with whom you interact in your capacity as an employee, officer or director of Travelers to solicit money, goods or a pledge of services for a charitable organization unless connected with a Travelers initiative or unless you have received authorization from the enterprise Chief Ethics and Compliance Officer or his/her designee.

G. Corporate Opportunities

Employees, officers and directors owe a duty to the Company to advance the Companys business interests when the opportunity to do so arises. Except with authorization from the enterprise Chief Ethics and Compliance Officer or his/her designee, employees, officers and directors are prohibited from personally taking

CONTACT US u

The provision of gifts and other things of value to government officials is strictly prohibited unless specifically permitted by a Travelers policy or pre-approved in writing by the enterprise Chief Ethics and Compliance Officer or his/her designee.

Pre-Approve


Anti-Bribery and Anti-CorruptionAs a representative of the Company, you are prohibited from directly or indirectly engaging in any form of bribery or corruption. You must not seek to influence the judgment of any government official or any other person by promising, offering or giving anything of value (e.g., money, loans or inappropriate gifts).

Bribery and corruption are wholly inconsistent with the Companys core values and Travelers has instituted policies, procedures and internal controls for complying with anti-bribery and anti-corruption laws. The Company strictly prohibits any promise, offer, or the provision of anything of value to any government official (as defined in the Conflicts of Interest/Giving of Gifts section above) or any other person for the purpose of improperly obtaining or retaining business, influencing action or obtaining any form of improper benefit. Anything of value is a broad concept that includes, without limitation, financial or other advantages, such as cash payments, loans, inappropriate gifts, travel, lodging, services, amenities, employment opportunities and internships, charitable donations and tickets to sporting and other events.

Payments made indirectly through a consultant, broker, agent, attorney, contractor or other third party are subject to the same restrictions, and it is your obligation to understand what such a party is doing on the Companys behalf.

(or directing a third party to take) a corporate opportunity that is identified through the use of Company property, information or other assets, or the individuals position at, or work with, the Company. In addition, except with authorization from the enterprise Chief Ethics and Compliance Officer or his/her designee, employees, officers and directors are prohibited from using Company property, information and assets or their Company position for personal gain or to compete with the Company.

H. Government Service

There may be occasions where employees, officers and directors will seek to or will be asked to serve in national, federal, state/provincial or local government. Such service may subject the Company, and the individual serving, to obligations and restrictions, and may present a conflict of interest.

Employees, officers and directors are required, in most circumstances, to obtain advance written authorization from the enterprise Chief Ethics and Compliance Officer or his/her designee when seeking to serve in national, federal, state/provincial or local government. This applies not only to elected and appointed offices, but to service at any level of government, including serving on or advising boards and commissions, as well. Additionally, given that certain jurisdictions may place restrictions and obligations on the Company when certain family members of Company employees, officers and directors serve in national, federal, state/provincial or local government, notice to the enterprise Chief Ethics and Compliance Officer or his/her designee is generally expected in these situations as well. Additional guidance on authorization and notification requirements related to you and your family members government service may be found in Travelers policies regarding government service and anti-money laundering, as applicable.

ProhibitedRequesting and receiving bribes, kickbacks and other improper payments is strictly prohibited.


In addition, Travelers strictly prohibits the giving of any gift or anything of value to government officials (federal, state, provincial, local) unless specifically permitted by a Travelers policy or preapproved in writing by the enterprise Chief Ethics and Compliance Officer or his/her designee. Thus, you should not give, offer or promise anything of value to a government official or such officials family members without first confirming that doing so is permissible under a Travelers policy or obtaining proper authorization from the enterprise Chief Ethics and Compliance Officer or his/her designee.

Requesting and receiving bribes, kickbacks and other improper payments is also strictly prohibited.

Additionally, sound business practices and applicable anti-bribery and anti-corruption laws require the Company to keep records that accurately and fairly reflect our transactions and maintain a system of internal accounting controls that provide reasonable assurances that transactions are properly recorded and executed in accordance with managements authorization.

All employees, officers and directors, no matter where they are located, are required to comply with the United States Foreign Corrupt Practices Act, in addition to all other applicable anti-bribery and anti-corruption laws, which may include, without limitation, the United Kingdom Bribery Act 2010, the Canadian Corruption of Foreign Public Officials Act and the Brazilian Anti-Corruption Law, all of which may be supplemented and amended from time to time.

For information on avoiding bribery and corruption, refer to the policies available electronically on the Policies and Standards site available on each countrys inside page or through other means.

Antitrust, Competition and Fair DealingTravelers employees, officers and directors are encouraged to compete vigorously in the marketplace; however, the Companys business affairs are expected to be conducted in a fair and lawful manner.

Travelers employees, officers and directors are encouraged to compete vigorously in the marketplace; however, the Companys business affairs are expected to be conducted in a fair and lawful manner. Travelers expects all employees, officers and directors to become familiar with antitrust and competition guidelines and to comply with all laws and regulations that promote fair and open competition among companies in all countries where the Company does business and to deal fairly with the Companys customers, suppliers, competitors and employees. Travelers will not engage in activity that has the effect of unlawfully limiting competition.

Travelers is subject to antitrust laws designed to preserve competition across industries and to protect consumers from unfair business arrangements and practices. The laws vary across jurisdictions, but generally prohibit activities that unreasonably inhibit or restrain competition, create a monopoly, abuse a dominant market position, artificially raise or maintain prices, or otherwise illegally hinder or disrupt normal commerce.

Many situations could create the potential for anti-competitive conduct and are expected to be avoided. These include:

Proposals from competitors to share or set prices or to allocate markets or customers.

Requests by customers, potential customers, competitors or brokers for Travelers to purposefully submit high quotes or for Travelers to join in a boycott of certain customers.

All forms of anti-competitive or deceptive conduct or unfair advantage through manipulation, concealment, collusion or misrepresentation of material facts are strictly prohibited.

Fair


Discussions with competitors, for example at industry trade association meetings, on competitively sensitive topics, such as pricing, costs and/or marketing strategies.

Suggestions to Travelers customers that failing to do business with one of Travelers business segments could jeopardize business with another Travelers business segment.

All forms of anti-competitive or deceptive conduct or unfair advantage through manipulation, concealment, collusion or misrepresentation of material facts are strictly prohibited.

Questions concerning antitrust implications should be referred to your internal Travelers legal counsel or the enterprise Chief Ethics and Compliance Officer before taking any action.

Buying or Selling SecuritiesInsider trading and the sharing of material, non-public information is against Company policy and may be illegal.

Trading in the stock or securities of a company, such as Travelers, by an employee, officer or director who is aware of material, non-public information may constitute insider trading, which is both illegal and against Company policy. Information is material if a reasonable investor would consider such information important in a decision to buy, hold or sell the securities. Information is non-public until it has been broadly disclosed to the marketplace (such as through a public filing with the Securities and Exchange Commission or the issuance of a press release) and the marketplace has had time to absorb the information.

The sharing of material, non-public information with any person (called tipping) other than another employee, officer or director, or a representative of or advisor to the Company, in each case who needs to know the information to perform their duties, is against Company policy and may also be illegal.

Questions about the propriety of any transaction in the Companys or any other companys stock, bonds or other securities should be directed to the Corporate Secretary or the General Counsel before undertaking the transaction.

Accuracy of Company Records and Finance-Related ReportingOur records must accurately and fairly reflect, in reasonable detail, the Companys assets, liabilities, revenues and expenses.

Travelers financial information and statements are prepared in compliance with generally accepted accounting principles and statutory accounting practices and procedures. Our records must accurately and fairly reflect, in reasonable detail, the Companys assets, liabilities, revenues and expenses.

The records, data and information owned, used and managed by Travelers must be accurate and complete. All employees, officers

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If you have a concern about the integrity or objectivity of the Companys financial statements or any other public disclosures made by the Company, or the quality or effectiveness of the Companys system of internal controls, you are expected to report that concern immediately.

Integrity


and directors are personally responsible for the integrity of the information, reports and records under their control. Making false or misleading statements to anyone, or asking someone else to do so, including to internal or external auditors, Travelers counsel, other Travelers employees or regulators may be a criminal act that may result in severe penalties. You should never withhold or fail to communicate information that should be brought to the attention of higher level management, and you should never ask someone to withhold or fail to communicate such information.

You must never take, directly or indirectly, any action to coerce, manipulate, mislead or fraudulently influence the Companys internal or external auditors in the performance of their audit or review of the Companys financial statements.

If you have a concern about the integrity or objectivity of the Companys financial statements or any other public disclosures made by the Company, or the quality or effectiveness of the Companys system of internal controls, you are expected to report that concern immediately. You should report the concern to the enterprise Chief Ethics and Compliance Officer or the Chief Financial Officer for your location. You may also provide notification by calling the Ethics Helpline. (See the Appendix for contact information.)

In addition, you may communicate any concern about Travelers accounting, internal controls or auditing matters directly to the Board of Directors, the non-employee Directors or the Audit Committee (parent company or, if outside the United States, local Audit Committee, if applicable). With respect to communicating such concerns in Canada, you may also contact the Chief Agent (where applicable) and/or external auditor. Communications by employees regarding accounting, internal controls or auditing matters may be made on an anonymous basis.

To (1) contact the Board of Directors of Travelers (Attn: Chair of the Board), (2) report concerns about Travelers accounting, internal accounting controls or auditing matters or other concerns to the Audit Committee (Attn: Lead Independent Director or Chair of the Audit Committee), (3) communicate with the non-employee members of the Board of Directors as a group (Attn: Chair of the Nominating and Governance Committee) or (4) communicate with Travelers management (Attn: Chief Executive Officer), mail correspondence to the following address:

The Travelers Companies, Inc. c/o Corporate Secretary 385 Washington Street Saint Paul, MN 55102-1396 U.S.A.

You may have additional reporting obligations under your local policies. These separate policies are available through the Policies and Standards site available on each countrys inside page or through other means.

Privacy and InformationAccess to information withinCompany systems or obtained from third parties is provided for authorized business purposes only.

In the course of your employment or affiliation with Travelers, you may have access to information about the Company,its current or prospective employees, customers, insureds, agents, claimants, suppliers and vendors or current or prospective business

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Any suspected oractual loss, theft or misuse of dfasf Information or inappropriate system access should be immediately reported to the enterpriseChief Ethics and Compliance Officeror his/her designee.


partners. Employees, officers and directors are expected to maintain the sadfasdfdsf of all such information, except when disclosure is authorized by the Company or required by law, regulation, or legal or judicial process.

asdf information asdfa Information) generally includes non-public information such as: internal informationabout Travelers business, such as financial, sales, marketing,claim, technical and business information, including profitand loss statements, business/marketing strategy and trade secrets; client, customer, policyholder, insured person, claimant, vendor, consultant and agent information, including personal information such as social security numbers and medical information; legal advice obtained; product and system information; and any compilation of this information or employee information obtained as part of your responsibilitiesat Travelers.

Access to asdfa Information within Company systems or obtained from third parties is provided for authorized business purposes only and is to be accessed only by individuals with legitimate business reasons to know about or have access tothe information.

You are expected to take precautionary measures to safeguard all asdf Information. You may not disclose asdfasdf Information to any unauthorized person, including otherTravelers employees. You should take steps to ensure that,to the extent asdfsdaf Information is transmitted,transported, filed, stored or disposed of, it is done so by meansdesigned to prevent unauthorized disclosure of, or access to,such information. You are expected to protect asdfasdf Information from misuse, using the information only to the extent necessary to perform your assigned responsibilities.Your obligation to safeguard adsfasdf Information extendsto all situations in which you may use such information,including when you are away from work or working remotely.

Any suspected or actual loss, theft or misuse of asdfasf Information or inappropriate system access should be immediately reported to the enterprise Chief Ethics and Compliance Officer or his/her designee.

Additional information regarding asdfadsf information,data breach, privacy and systems use is available electronically through the Policies and Standards site available on eachcountrys inside page or through other means.

Protection and Proper Use of Corporate AssetsSafeguarding the assets of the Companyand its customers and vendors is a personal responsibility of all employees, officersand directors.

All employees, officers and directors are responsible for personally safeguarding the tangible and intangible assets ofthe Company and its customers and vendors that are under their control. Company assets may only be used for legitimate business purposes and may not be used for personal benefitor for any purpose which may compete with the business ofthe Company absent authorization from the enterprise ChiefEthics and Compliance Officer or his/her designee. Suchassets include intellectual property, sdfasdf Information,electronic resources, physical property and services.Intellectual property is an important asset of the Companythat provides the Company a competitive advantage in themarketplace, and includes patents, copyrights, trademarks/branding and certain types of asdfasdf Information(including trade secrets). For additional information regarding the protection of the Companys intellectual property, referto the policies available electronically on the Policies andStandards site on each countrys inside page or throughother means.

Upon termination of your employment or affiliation with the Company, you are required to return all Company property, including, without limitation, all Company identification cards, keys, credit cards, computers, cellular telephones, intellectual property, and asdfadsf Information (in all forms, whether electronic, in paper or any other medium).

Travelers allows its employees, officers and directors to make occasional inconsequential personal use of its resources (such as use of Company telephones to receive or make limited personal telephone calls), provided that such use complies with legal and ethical requirements and with all applicable Company policies. You are expected to use good business judgment when you are using these resources. Information and communication systems, such as computer systems and the information accessible through these systems, are valuable company assets for which individual users are responsible, whether the assets are used in a company office, at home orin any other location.


Disclosure of Crimes and Penalties In certain jurisdictions, Travelers is, by law, prohibited from employing or engaging persons convicted of certain crimes, or subject to certain civil or regulatory penalties. In addition, there may be legal or regulatory restrictions concerning criminal convictions that may hinder your ability to obtain or retain a license or regulatory approval required for your position. Accordingly, you may be required to notify the Company of certain criminal offenses. For information regarding these notification obligations, refer to the policies available electronically on the Policies and Standards site on each countrys inside page or through other means.

Diversity and Fair Employment PracticesTravelers believes that diversity in our staff is important to our success, and we seek to recruit, develop and retain the most talented people from a diverse candidate pool.

In addition, we are fully committed to equal employment opportunity and compliance with the full range of fair employment practice and nondiscrimination laws in place in the countries in which we do business. The Company provides equal employment opportunity to all employees and applicants

for employment free from unlawful discrimination based on race, color, religion, gender, gender identity, age, national origin, disability, veteran status, marital status, sexual orientation, genetic information or any other status or condition protected by law.

Claim HandlingTravelers policy is to handle claims fairly by paying what we owe and following the terms of the applicable insurance policies and all claim handling standards contained in the applicable statutes and regulations. Claim personnel are expected to act promptly and in good faith when handling claims. In addition, all instances of suspected fraud will be investigated and reported to the proper authorities.

PoliciesWhile not part of this Code of Conduct, the Companys other policies and standards of conduct, which may differ by business area and jurisdiction, are developed to support and reinforce the principles set forth in this Code of Conduct. These various separate policies and standards can be assessed electronically through the Policies and Standards site available on each countrys inside page or through other means.

Crime

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You may be required to notify the Company of certain criminal offenses. For information regarding these notification obligations, refer to the policies available electronically on the Policies and Standards site on each countrys inside page or through other means.


ViolationsAll Company employees, officers and directors are expected to understand and comply with the principles set forth in this Code of Conduct. Violations of certain provisions of this Code of Conduct (e.g., Buying or Selling Securities; Anti-Bribery and Anti-Corruption; and Antitrust, Competition and Fair Dealing) may result in severe penalties, sanctions and other consequences being imposed on the Company. Violating as well as encouraging others to violate this Code of Conduct, the Companys policies, or applicable laws and regulations, may result in disciplinary action. Disciplinary action may include immediate termination of your employment or relationship with the Company.

Furthermore, you will be held personally responsible for any improper or illegal acts you commit during your relationship with the Company. You may also be held responsible for the action or inaction of others if you knew about, should have known about, or encouraged their misconduct. Your activities may also be reported to, or otherwise reviewed by, regulators and other authorities, which could result in criminal or civil penalties, including imprisonment.

Exceptions and AuthorityThe enterprise Chief Ethics and Compliance Officer is responsible for interpreting and applying the Code of Conduct in specific situations in which questions may arise. The enterprise Chief Ethics and Compliance Officer may grant exceptions to, or waivers of compliance with, certain provisions of the Code of Conduct in appropriate circumstances. Any employee who believes that a situation may warrant such an exception or waiver should contact the enterprise Chief Ethics and Compliance Officer. Any waiver of compliance with the Code of Conduct for executive officers or directors of the Company will be made via written request to and approved only by the Board of Directors of the Company or a committee of the Board of Directors. Any such waivers of compliance granted by the Board of Directors or any of its committees will be promptly disclosed in accordance with applicable rules and regulations.

Any authority granted in this Code of Conduct to the enterprise Chief Ethics and Compliance Officer shall be deemed to be granted to the General Counsel as well. In no event, however, may any person grant an exception or make an interpretation as to himself or herself.

Violating as well as encouraging others to violate this Code of Conduct, the Companys policies, or applicable laws and regulations, may result in disciplinary action, including immediate termination of your employment or relationship with the Company.

Disciplinary Action


I certify that: I have reviewed, understand and agree to comply with the contents of

The Travelers Companies, Inc. (and its subsidiaries) Code of Business Conduct and Ethics.

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