Generali SpA

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    Anti-corruption

    We condemn and combat all forms of corruption and financial crime. We make our position clear in the Code of Conduct.

    As a participant of the Italian network of UN Global Compact and that of Trasparency Internationalwe undertake to share, support and apply the principle of fighting against corruption in our spheres of influence.

    Our approach

    We strive to act responsibly, not limiting ourselves to simply respecting all national and international laws but promoting ethical and transparent conduct in order to strengthen our reputation among our stakeholders and increase their trust.

    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 regularly monitor our exposure to all compliance risks in order to minimise potential damage to our reputation and economic losses deriving from the violation of laws in force, including those designed to prevent corruption. The Group policies have defined standards of conduct valid all over  the world with the introduction of compliance programmes that include actions to monitor the biggest risks.

    Training

    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.

    REPORTING

    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 initiatives like Our Code in Brief, cartoon videos, and Integrity Week, two global internal campaigns focused on strengthening trust and integrity and combating corruption as well as the roles of the Compliance department.

    We are committed to combating fraud and this is why we have developed the Claims Fraud Program to monitor the entire value chain in the claims management and to identify the critical stages where action needs to be taken.

    Our commitment to combating fraud is focused on three areas:

    • ensuring management quality and greater client focus
    • strengthening cost control and operational efficiency
    • developing cooperation and a positive atmosphere in the community.


    The programme involves all business units through:

    • cooperation between the departments involved in claims management and dedicated investigation units
    • the identification of fraud and of processes to prevent any losses due to fraud
    • the development of control and monitoring systems to detect fraud, the investigation of suspected cases, and reporting and trend monitoring systems.


    Thanks to the measures implemented, we recorded significant results in the fight against fraud. Our aim is to further improve, through the efforts made by all the people involved in damage compensation activities and thanks to advanced process analysis systems.

    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 adopted a specific procedure with a view to ensuring that the relationships with the related-parties meet the interests of the Company and/or the Group and are executed in compliance with market conditions.

    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 component parts of the model – and several special sections, each of which contains a legal analysis of the individual offences covered by the Decree, 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 Surveillance Body in this regard.