Combatting corruption and bribery

At UNIQA we regard compliance with all relevant statutory regulations, internal Group policies and ethical principles to be an essential part of responsible business practice. A key factor underlying this principle is our awareness that the insurance industry is fundamentally based on trust. Compliance risks such as corruption and bribery have potential economic and legal consequences. The mere suspicion of corruption and bribery can lead to reputational damage and a loss of trust on the part of business partners and customers. Therefore, responsible behaviour is an important basis for our actions.

In addition to top-quality products and services, UNIQA also strives for the highest standards for employee conduct. That is why we set internal standards for ethical behaviour in our Code of Conduct that go beyond those of the applicable laws, and which are equally binding in all areas of the company. The Code of Conduct is communicated to all employees by the local compliance functions. Its content is also part of the mandatory annual compliance training. The Group Compliance Policy and the Group Compliance Standard describe how the compliance function is organised within the UNIQA Group and contain regulations on key compliance topics, such as preventing corruption, dealing with indications of non-compliance or tasks in connection with the topic of sustainability. The Group compliance team is responsible for creating all these regulations and implementing the compliance programme throughout the entire Group. This central unit is supported by a separate local compliance function within every insurance company of the UNIQA Group.

In the 2023 reporting year, we continued to pursue our goal of zero violations with respect to legal regulations. Despite our legal initiatives and compliance measures, there were four cases of non-compliance with laws and regulations in the reporting year that resulted in monetary penalties totalling €276,700 (2022: €19,572). In the 2023 reporting year, €445,778 in fines were also paid for two violations of laws and regulations from previous years (of which €395,778 in Hungary and €50,000 in Serbia). In the course of the reporting year, a total of nine proceedings were brought due to significant violations of applicable laws and regulations, against which appeals were lodged during the reporting period. Fines were imposed in six of these cases and non-monetary sanctions were imposed in three cases.

In contrast, as in the previous year, no confirmed breaches of anti-corruption or money laundering legislation were recorded in the 2023 reporting year. In 2022, there were proceedings due to anti-competitive behaviour, cartel and monopoly practices. In the course of settlement talks, the UNIQA Group was obliged to pay €422,330; this fine was the lowest of all the insurance companies investigated by the competition authority. There were no further legal proceedings due to anti-competitive behaviour, cartels or monopolies in 2023.

In the reporting year as in the previous year, no violations of regulations resulting in fines or sanctions or of voluntary codes of conduct were identified in connection with product and service information and labelling. In contrast to the previous year, in which one incident occurred that resulted in a warning, a total of eight incidents were registered in the reporting year, each of which resulted in a warning.

In the reporting year, the anti-corruption regulations were communicated to all members of the Supervisory Board and Management Board of the UNIQA Group, as well as to employees of UNIQA Austria. The e-learning training course on the Code of Conduct was successfully completed by 66.6 per cent of the nine members of the UNIQA Group Management Board and 88.3 per cent of UNIQA Austria employees overall. For members of the UNIQA Group Supervisory Board, the training focus in 2023 was on money laundering prevention and issuer compliance. In 2024, members of the UNIQA Group Supervisory Board will focus on anti-corruption training. In the international insurance companies¹⁾, 95.3 per cent of members of the management bodies and 76.6 per cent of employees took part in anti-corruption training.

In 2023, the EU Whistleblower Directive was transposed into several national laws. Since 2018, the UNIQA Group has had a portal where information on non-compliance in the UNIQA Group’s insurance companies can be submitted. The portal was updated in 2023 and expanded to include non-insurance companies. Information can be submitted by UNIQA employees, but also by external persons, which goes beyond the legal obligation. This is of course also anonymous.

1) The key figures include data from the following countries: Albania, Bosnia and Herzegovina, Bulgaria, Croatia, Czechia, Hungary, Kosovo, Liechtenstein, Montenegro, North Macedonia, Poland, Romania, Russia, Serbia, Slovakia, Switzerland and Ukraine.