Compliance and combatting corruption and bribery

As a company that acts responsibly, we believe compliance with all relevant statutory regulations, internal company guidelines and ethical principles is essential. 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 but is also a cornerstone of our long-term success.

Compliance and anti-corruption at 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 standard approach across the entire Group, and is also supported by a separate local Compliance function in each UNIQA Group insurance company. Other management responsibilities of the Group Compliance function include verifying that internal and external guidelines are being followed. We carry out standardised inspections (company visits), which were conducted remotely in 2022, and in 2021 we introduced the “Check of Focus Areas” tool. This ensured checks were conducted on several UNIQA Group insurance companies as regards their observance of selected requirements regarding general compliance, prevention of money laundering and the Foreign Account Tax Compliance Act (FATCA). The results were then reported to the relevant local member of the Management Board in the form of a written report. No incidents of the key figure “Confirmed incidents of corruption and actions taken” were reported during the financial year.

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 provides clear guidance on the most important compliance topics. The principles and regulations laid down in the Code of Conduct apply to all areas of our daily work and are mandatory for our Management Board, Supervisory Board and employees alike. There are special regulations in place for specific compliance topics, such as prevention of money laundering, implementation of the Foreign Account Tax Compliance Act (FATCA), 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.

We use an e-learning module to provide ongoing compliance training, covering in particular topics such as issuer compliance, donations, whistleblowing and conflicts of interest.

Targets and target achievement: compliance and combatting corruption and bribery

Subject

Target achievement in 2022

2023 targets

Compliance management system

The existing compliance management system is utilised and monitored in all significant Group companies with the aid of suitable tools.

Compliance processes will be revised in line with the upcoming regulatory requirements regarding the Corporate Sustainability Due Diligence Directive (CSDDD) and monitored within the core business.

Anti-corruption measures

Application of the Group-wide system to recognise sanctioned and politically exposed persons continued successfully during the financial year.

The Compliance function at UNIQA Austria is continuing the initiative to enhance awareness of compliance and anti-corruption measures among sales employees.

Solvency II
European Union Directive on publication obligations and solvency rules for the equity base of an insurance company.
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