Our rejection of all forms of corruption, including the payment of bribes and extortion, is enshrined in our Code of Conduct.
As a participant of the UN Global Compact, we undertake to share, support and apply the principle of fighting against corruption in our spheres of influence.
We ask all our stakeholders to engage in conduct to counter corruption and we also adopt measures to prevent conduct that is not in line with the principles of fairness, legality and transparency. For example, we have produced a detailed set of guidelines on giving or receiving gifts in dealings with public officials and business partners.
We believe that training is an important element of managing the risk associated with the different kinds of corruption, as it builds the necessary awareness and skills needed to stop them from happening. We provide adequate and continuous training for employees who are more likely to come into contact with corrupt practices and phenomena. The aim is to equip them with the skills needed to identify and manage activities potentially associated with the various forms of corrupt practices. Training is provided through dedicated meetings and courses delivered primarily via e-learning platforms.
Alleged breaches of the Code of Conduct attributable to instances of corruption (including fraud, conflicts of interest, money laundering, etc.) can be reported – anonymously where permitted by law – through the channels set out in the Code.
The various forms of corruption the Group is committed to combating are set out below.
We expressly affirms our rejection of all forms of corruption in our Code of Conduct.
In particular, our employees and third parties who operate on behalf of the Group (agents, suppliers, consultants, etc.) must not offer or accept gifts or entertainment from public officials or business partners (or their relatives or business partners) that could be perceived as a bribe. The obligation to abstain from this conduct applies without exception in the case of unlawful payments such as bribes, payoffs or facilitating payments, which aim to speed up or facilitate the execution of routine operations. Gifts, entertainment or other benefits may only be offered or received provided they are of negligible value, are suited to the circumstances, are work-related, are permitted by local law and conform to the local commercial practice in use.
In addition, we do not endorse any event or initiative that is essentially or exclusively of a political nature, we refrain from exercising direct or indirect pressure on political representatives and we do not make any contributions to trade union associations.
The declaration setting out our zero-tolerance approach to any form of corruption in our Code of Conduct is backed up by a variety of initiatives to raise awareness of our position, including communications and employee training campaigns like the Let’s Talk Ethics initiative – which takes the form of a series of cartoon strips and detailed texts on specific aspects of the Code of Conduct.
We have a policy to combat external fraud, which includes any intentional act to obtain a profit from the insurance company, such as claims for damage that did not occur or that is not related to the notified event (the amount of which is therefore inflated) and misrepresentation at the time of signing the policy or claim notification.
One of the ways we combat fraud is through our Cognitive Interview project. Launched in 2014, the project saw 12 fraud managers from nine different Group companies come together to work out how best to implement this investigative technique – based on active listening and conversation – in terms of its organisational impact, the criteria for selecting cases for scrutiny and how to approach communications with the counterparty.
Initial results have seen a significant reduction in the time required to manage suspect cases: in particular, long desk inquiries and the involvement of external investigators have not been necessary in 57% of the claims involved in the project.
We have increased the exchange of skills and knowledge between our companies in terms of best practices on identifying and preventing problematic and potentially fraudulent situations. Our claims offices also contain special investigative units, with more than 200 specialists in our European companies alone. These units assist in training claims handlers, providing them the necessary skills to detect and deal with fraudulent claims, while remaining in constant contact with our insurance companies through national trade associations.
We are also committed to stopping internal fraud, which is defined as an intentional act illegally performed by one or more staff members in order to obtain an undue profit for themselves or for others, which causes or may cause financial or non-financial harm to the Group. In this regard, in 2010 an Internal Fraud Policy was issued by Assicurazioni Generali, which was subsequently adopted by all our companies, that sets out the rules and organisational measures for setting up an efficient and effective system to combat internal fraud.
As stated in our Code of Conduct, we are committed to the international fight against money laundering and terrorist financing; we work to combat all actions that could be construed as providing support for these criminal activities. The Group Anti-Money Laundering Policy – approved by Assicurazioni Generali and subsequently adopted by all our companies worldwide – sets out guidelines and minimum standards our companies are required to follow to prevent money laundering and the financing of international terrorism. The document follows the requirements set out in Directive 2005/60/EC and the recommendations of the Financial Action Task Force (FATF). The main aim of the policy is to identify what actions should be taken to prevent the use of financial transactions to launder money, such as customer due diligence, continuous monitoring of clients and transactions, keeping a register of these checks, identifying suspicious transactions on the basis of defined risk indicators and reporting them to the local Financial Information Office. The document also sets out responsibilities, tasks and operational processes to prevent risks arising.
The Code of Conduct and Group Rules set out specific obligations on situations where there may be a conflict of interest, such as to refrain from entering into these situations, to declare them as soon as they arise, and to seek prior authorisation for external activities, as well as procedures for dealing with related parties. Furthermore, in accordance with the Consob Regulation adopted through Resolution No. 17221/2010, we have produced a document setting out rules on related-party transactions entered into by Assicurazioni Generali and its subsidiaries, the aim of which is to ensure that these transactions are performed in accordance with the principles of transparency and are substantively and procedurally correct.
We have adopted an Organisational and Management Model to prevent the commission of offences under Italian Legislative Decree No. 231/2001 by employees, agents or anyone who has dealings with the Group, thereby avoiding incurring corporate administrative liability.
The document comprises a general section – which, among other things, sets out the role of the Supervisory Body appointed to oversee the functioning of the model, ensuring compliance with it and keeping it updated – and several special sections, one for each “offence category”. These sections contain the general principles of conduct that must be followed in areas potentially vulnerable to offences, the company functions involved, the at-risk activities, the specific offences that potentially could occur, how they might be committed or the actions that could facilitate them being committed, preventive controls and the responsibilities of the Supervisory Body in this regard.