Compliance and combatting corruption and bribery

We believe compliance with all relevant statutory regulations, internal company guidelines and ethical principles is essential as a company that acts responsibly. The insurance business requires a high degree of trust; lawful and ethical action therefore not only has a decisive impact on the reputation of the entire UNIQA Group, it is also a fundamental requirement for our long-term success.

The topics of compliance and combatting corruption at a Group level are covered by the Group Legal and Compliance department, which reports directly to the CFO. This department is responsible for establishing the basis for a uniform approach across the entire Group, and is also supported by a separate local Compliance function in each UNIQA Group insurance company. The Group Compliance function’s other management duties include reviewing compliance with internal and external requirements. In 2021, we introduced the “Check of Focus Areas” tool to replace the default company visits. This ensured checks were conducted on each UNIQA Group insurance group as regards their observance of selected requirements regarding general compliance, prevention of money laundering and FATCA. The results were then reported to the respective local member of the Management Board in the form of a written report.

A key tool for managing compliance at UNIQA is the annual compliance conference, which serves as a platform for distributing new information and exchanging experiences within the Group.

The UNIQA Group Code of Conduct was extensively revised in 2020, with the new version rolled out and communicated in 2021. The Code of Conduct provides clear guidance on the most important compliance topics. It reflects the UNIQA 3.0 strategy in the same way as our guiding principles and our corporate culture. The principles and regulations laid down in the Code of Conduct apply to all areas of our daily work and are equally mandatory for our Management Board, Supervisory Board and all employees. There are special regulations in place for specific compliance topics, such as prevention of money laundering, implementation of the Foreign Account Tax Compliance Act FACTA, Common Reporting Standard and Solvency II. They are dealt with in the form of specific policies, standards and manuals along with concrete instructions on selected individual topics. The following topics have been newly regulated and/or supplemented by way of the new version: Donations and other gifts to and from political parties, organisations closely affiliated with political parties and parties campaigning in elections are no longer permitted. An exception to this rule is the sponsorship of events organised by political parties or organisations they are closely affiliated with in which no party-related political content is discussed and that are accessible to the public.

The Governance, Risk and Compliance (GRC) tool was rolled out in all Group insurance companies in 2021. An interdisciplinary project to develop a tool with several modules (compliance, data protection, risk management and IT security) that aims to reinforce an integrated approach to documenting risks was completed here. Compliance risks and risk-minimising measures are recorded and administered as a whole in the compliance module, thus creating the basis for uniform reporting. Local compliance officers, anti-money laundering officers and FATCA-responsible officers have already reported to the Group functions and to the local Management Boards and Supervisory Boards in 2021 using the data recorded in the GRC tool as the basis.

The e-learning module on the topic of compliance was revised in 2021 and approved for mandatory participation for all back office and sales force employees in Austria at the end of the year. This module focuses on gifts, whistleblowing and conflicts of interest. Participants can also practice answering various questions at the end of the module. Other e-learning modules on the prevention of money laundering have since been made available.

In 2021, we evaluated the existing continuous areas of confidentiality and updated them in line with the structural, organisational and personnel-related changes made. In order to take the changing working conditions into account, we launched regular virtual training sessions on the subject of issuer compliance for our new employees. Two to three dates each quarter are set aside and offered for this purpose. In addition, we have made use of a specific format to train our managers on the most important topics and developments in issuer compliance. The Compliance Officer reported to the Group Management Board on a regular basis on the most important issuer compliance matters and also produced an extensive Group report. Moreover, regular discussions were held on current issues with the Management Board member responsible for this topic.