Financial crimes compliance

Assicurazione Generali ("AG") and each of its majority-owned subsidiaries (“Generali”) are firmly and highly committed to participating in international efforts to combat money laundering and the funding of terrorist activities.

AG is a publicly traded and a registered financial holding company headquartered in Trieste, Italy, regulated by the Istituto per la Vigilanza sulle Assicurazioni (“IVASS”). Generali is also regulated by other various regulatory organizations, including self-regulatory organizations, as well as other governmental agencies that have supervisory authority over certain legal entities in those jurisdictions where Generali operates.

Generali has implemented a risk-based global Anti-Money Laundering ("AML") Compliance Program ("AML Program") designed to comply with AML laws and regulations in Italy and Europe, including the Directive (EU) 2015/849 (the 5th Anti-Money Laundering Directive), and other applicable laws and regulations relating to the prevention of money laundering and terrorist financing in the jurisdictions where Generali operates. The AML Program provides guidance to all employees and persons acting on behalf of the Group, requiring them to conduct business in accordance with applicable AML laws, rules, and regulations.

In accordance with the aforementioned Generali Group high standards, Generali has established a Group Sanctions Compliance Program (“GSC Program”) which defines the minimum standards which all Generali Group Entities must comply with and consisting of the following elements: (i) procedures, systems, and internal controls designed to comply with applicable sanctions regimes; (ii) roles and responsibilities for the implementation and operation of the GSC Program; (iii) compliance & independent testing; (iv) an ongoing training program; and (v) reporting and record keeping.