Fight against corruption

As mentioned, the issue of corruption in its various forms is addressed in the Code of Conduct and its Group rules, as well as in other tools (policies, guidelines, regulations and practices.

Almost all of the countries in which we operate have legislation that prohibits the corruption of public and private entities and are required to comply with said legislation on pain of penal and/or civil sanctions. In this regard, we note that in Italy, the crime of corruption between private individuals was recently included in the list of offences provided for by Legislative Decree 231/2001. As a result, we have reviewed and updated our Organisational and Management Model and performed a new mapping of risk areas in the context of business processes, identifying and implementing business controls to prevent the commission of such offences.

In addition, we require all of our stakeholders to engage in conduct to counter corruption and we adopt suitable measures to prevent conduct that is not in keeping with the principles of correctness, legality and transparency: specific policies; adequate internal controls; compliance programmes; risk assessment procedures that are consistent with the size and structure of the company, as well as the nature, scope and place of business; financial and accounting procedures that ensure that the books, records and accounts are kept in the correct manner and are not used to engage in corruption or conceal acts of corruption; and training and awareness initiatives.

The Code of Conduct and its Group rules also address the issue of gifts that employees and third parties operating on behalf of the Group (agents, suppliers, consultants, etc.) should not offer or accept from public officials or business partners (or their relatives or business partners). 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.

Among the measures envisaged to prevent the risk of corruption, we do not endorse any event or initiative essentially or exclusively of a political nature, refrain from exercising direct or indirect pressure on political representatives and do not make any contributions to associations in order to apply political pressure.

Aware of the fact that charity and sponsorship contributions may be used for corrupt purposes, we require specific preventive checks to be conducted on the beneficiaries and provides instructions on how to make payments. Similarly, in merger and acquisition transactions, we require due diligence to be performed in advance, to identify any instances of corruption, considering a reasonable period of time prior to the completion date of such transactions.

Again in order to prevent possible cases of corruption, relationships with business partners (agents and other intermediaries, consultants, etc.) must be documented by written agreements that refer to the Group anti-corruption policy and any payments for their services must comply with market conditions and not be made to ciphered or numbered accounts.

For situations where the possibility of conflict of interest is identified, specific measures are required, such as abstention, declaration at the time of recruitment, prior authorisation for conducting activities outside the company, and procedures regarding related parties. In this regard, in accordance with the provisions of the Consob Regulation adopted by means of Resolution n.17221/2010, a document has been prepared that governs related party transactions entered into, not only by Assicurazioni Generali but also by its subsidiaries, with the objective of ensuring that such transactions are carried out in observance of the principles of transparency and substantive and procedural fairness.

Staying in the context of offences that constitute other forms of corruption, Generali has adopted a series of measures to combat fraud, a fairly widespread practice in the insurance business, especially with regard to external fraud, which includes any intentional act to obtain a profit from the insurance company, such as, for example, claims for damage that did not occur or that is not related to the notified event (and thus increasing the claim expenses) and misrepresentation at the time of signing the policy or claim notification.
Enforcement measures put in place include the continuous exchange of best practices and collaboration between members of the local insurance network (for example, partnerships in Italy and Germany use national claim databases to help identify potential fraudulent claims), the use of predictive models and special investigative techniques and other Group initiatives to improve the processes of detection, investigation and prevention of anomalous or potentially fraudulent positions. Our claims departments also have special investigative units consisting of more than 200 specialists throughout our companies in Europe. These units are involved in defining guidelines, participating in local meetings to communicate anti-fraud issues, and training claims handlers to provide them with the necessary skills for identifying and combating fraudulent claims, and are in constant contact with the companies through the national trade associations.

In order to discourage and combat any type of behaviour engaged in by collaborators to the detriment of the Group, we have defined a set of principles and organisational measures, contained in the Internal Fraud Policy. The document was issued by Assicurazioni Generali in 2010 and subsequently adopted by all Group companies.

The fight against money laundering and terrorist financing is another central concern for the Group. We have developed guidelines and minimum standards of conduct which Group companies must comply with, including recommendations by the Financial Action Task Force and the relevant provisions contained in Directive 2005/60/EC. The Group Anti-Money Laundering Policy was approved by Assicurazioni Generali in 2012 and subsequently adopted by all Group companies across the world. In particular, the document sets out the responsibilities, duties and operational procedures related to risk management and highlights the behaviours to be adopted to prevent the use of financial transactions for the purpose of money laundering or terrorist financing. These measures include the performance of customer due diligence, the maintenance of a register populated with data obtained from this process, the identification of suspicious customers and/or transactions on the basis of risk indicators defined and the reporting of such transactions to the local Financial Information Unit, adequate controls, the use of appropriate management tools, the preparation of a detailed report on the matter and the prompt notification to the Head Office department in relation to any events that may expose the Group to high reputational risk.

Training is an important element of the management of risk associated with the different corrupt practices as it creates internal awareness and the skills needed to prevent cases of corruption.
Therefore, we offer adequate and continuous training to our employees who are more likely to come into contact with corrupt practices and phenomena, and, if necessary, our agents and their collaborators. The objective is to provide them with the necessary elements to identify and manage activities that are potentially related to these forms of behaviour.
Training is provided through specific meetings and courses delivered primarily through e-learning platforms. This solution is used, for example, to communicate to all employees and agents of the Group Italian companies the content and principles of the Organisational and Management Model, as well as to provide training on money laundering and terrorist financing to employees of the Group Italian companies who are obliged to respect the rules, as well as agents and their collaborators.

Assicurazioni Generali S.p.A. - C.F. e P.IVA 00079760328