The following code of ethics (the "Financial Code of Ethics") of Alleghany
Corporation (the "Company") applies to the Company's chief executive officer,
chief financial officer, chief accounting officer, vice president for tax
matters and all professionals serving in a finance, accounting, treasury or tax
role (the "Financial Officers") and supplements the provisions of the Alleghany
Code of Business Conduct and Ethics.
a. Act ethically and honestly, avoiding actual or
apparent conflicts of interest between personal and professional relationships.
b. Report to the General Counsel of the Company any proposed transaction or
relationship that reasonably could be expected to give rise to such a conflict.
c. Respect the confidentiality of non-public information about the Company or
its subsidiaries obtained or created in connection with one's activities except
when authorized or otherwise required by applicable law or regulation or legal
or regulatory process.
d. Provide full, fair, accurate, timely and understandable disclosure in reports
and documents that the Company files with, or submits to, the Securities and
Exchange Commission and in other public communications made by the Company.
e. Comply with all applicable governmental laws, rules and regulations.
f. Promptly report to the General Counsel or Chairman of the Company's Audit
Committee (i) any significant deficiencies or material weaknesses in the design
or operation of the Company's internal control over financial reporting which
is reasonably likely to adversely affect the Company's ability to record,
process, summarize and report financial information, and (ii) any fraud,
whether or not material, that involves management or other employees who have a
significant role in the Company's internal control over financial reporting.
g. Promptly report any possible violation of this Financial Code of Ethics to
the General Counsel of the Company or to the Chairman of the Company's Audit
Committee.
Any violation of this Financial Code of Ethics may result in disciplinary
action, up to and including termination of employment. Violations of this Code
of Ethics may also constitute violations of law and may result in civil and
criminal penalties for the Financial Officers involved and/or the Company.
Any questions regarding the best course of action in a particular situation
should be directed to the General Counsel.