Laws of the People's Republic of China

Reply of China Insurance Regulatory Commission about the Legal Status of Individual Insurance Agents

October 9, 2006

Insurance Regulatory Bureau of Guizhou Province:

We have received your Request for Instructions about the Legal Status of Individual Insurance Agents in Insurance Companies. Upon deliberation, we hereby render a reply as follows:

1.

In accordance with Articles 125 and 128 of the Insurance Law of the People's Republic of China (hereinafter referred to as the Insurance Law), individual insurance agents are a kind of insurance agents. They have a principal-agent relationship with insurance companies.

2.

In specific cases, whether an operator of an insurance company is an individual insurance agent as well as whether the operator has a principal-agent relationship with the insurance company shall be determined according to the legal nature of the specific agreement concluded between them.

3.

In accordance with Article 136 of the Insurance Law, an insurance company shall be responsible for training and managing its individual insurance agents so as to ensure the professional ethics and quality of its individual insurance agents.