Eco-Efficient Operations: Environmental Policy & Management System

As outlined in our Code of Business Conduct and Ethics, it is the company’s policy to comply with all applicable laws, rules and regulations; this includes all relevant environmental regulations. The Travelers Environmental Policy, approved by senior management, outlines some of the steps we take to operate more efficiently and in an environmentally conscious manner, including:

• Reviewing our equipment and technology and installing more efficient versions when appropriate.
• Conducting assessments with utility providers to better understand and manage our energy usage.
• Monitoring waste output to ensure we recycle as much as possible.

In addition, all Travelers-owned campuses are ENERGY STAR^® certified, which means that we are in the top quartile in terms of energy performance standards and undergo an annual recertification process.

Travelers continues to analyze the company’s operational impacts on the environment and works to minimize negative impacts. We utilize an environmental management system that regularly reviews our operations to measure our impacts and to identify opportunities that increase efficiency and reduce costs. Some of the key elements of our environmental management system include:

• Periodic review of facilities.
• Evaluating emerging technologies, such as alternative energy, and their potential use in our facilities.
• Partnering with power and other utility providers to review our operations and, when available, leveraging their incentive programs to help fund our improvements.
• Evaluating potential changes to energy regulations that may impact our costs and operations.
• Using technology to fine-tune operational parameters.
• Minimizing and recycling as much waste as possible.
• Evaluating how to be more efficient in space utilization, which has led to the introduction of a new open workspace environment that is designed to increase operational efficiency and decrease our need for office space, which will further minimize our impact on the environment.

Our Corporate Real Estate team conducts ongoing facilities assessments at all our owned locations. We also take these assessments into account when developing our capital expenditure plan.

As stated in our Supplier Code of Conduct, we expect our suppliers to comply with applicable environmental laws and to work to minimize any negative environmental impact from their operations, including by reducing or mitigating emissions, increasing sustainable use of natural resources and reducing or eliminating waste. Our Procurement team also oversees our comprehensive supplier selection and supply chain management processes, including the review of climate and environmental considerations, where appropriate.

After selection, Travelers uses a risk-based approach to monitor news alerts for certain suppliers, which includes monitoring for negative news relating to the supplier’s environmental issues and ethical practices.