Code of Conduct

Among the documents mentioned above, the Code of Conduct, which replaced the existing Ethical Code of the Group, is of primary importance. The document is supplemented by a system of Group Rules that provide greater operational detail on specific topics, such as the promotion of diversity and inclusion, conflicts of interest and the fight against corruption, personal data protection and the reporting of improper conduct.

The Code and its Group Rules were approved by the Board of Directors of the Parent Company on 14 December 2012 and have been adopted or are in the process of being adopted by all Group companies. Where applicable, adoption is preceded by dialogue with the relevant trade unions, which, in some cases, is still in progress (e.g. in Austria, France and Germany).

The Code of Conduct is applicable to all Group companies, operating in more than 60 countries worldwide, and sets the minimum standards of conduct that employees and those acting on behalf of the Group (e.g. consultants, suppliers and agents) should observe when carrying out their business activities. Therefore, these standards represent what the Group offers to its stakeholders in the relationships it maintains with them. The communication of these standards to employees is an important role assigned to the managers, who are required to display exemplary conduct and promote a culture of ethics and compliance with internal rules and the regulations in force in the various countries. Managers are also responsible for promoting a welcoming and supportive working environment.

In order for the Code to be applied and become an everyday reference point for the entire organisation, it is important to ensure that it is widely communicated and easily accessible. For this reason, in 2013 we translated the Code into all the languages of the countries in which we operate and published it, in the relevant languages, on the Group website and the websites of the various Group companies.

During 2013, we also committed to making a package of awareness and training initiatives available to employees. We are currently rolling out an e-learning course providing an overview of the Code to all employees, while managers will also be involved in specific training activities. In order to ensure greater involvement in relation to the topics covered by the Code, a publishing plan was launched on the We, Generali Portal which will last until 2015 and will include the regular publication of articles and cartoons dealing with individual topics related to the Code.

We encourage everyone to maintain an open dialogue with the Group companies. Any request for clarification, or to report a concern or inappropriate conduct can be addressed directly to management or to the relevant departments responsible for human resource management or control functions (Internal Audit and Compliance).
Since March 2014, any questionable conduct relating to financial management, auditing or accounting, the use of means of payment or corruption can be reported to the Generali Group Compliance Helpline, a dedicated internet and telephone channel operated by a third party provider. This channel is available 24/7, all year round, in all the languages of the countries in which the Group operates and complies with the recommendations of the European Commission, applying them to all Group companies, even those based in countries where statutory requirements are less stringent, according to Generali chosen approach. In particular, this approach has led us to define a specific data protection policy providing the maximum protection guaranteed within the European Union, which has been extended to all the countries in which we operate.
In countries where it is permitted by law, reports can also be submitted anonymously.
The Group ensures that anyone who submits a report in good faith is protected from any type of retaliation.

In 2013, 384 reports were presented at Group level, of which 14 related to human rights issues and to 272 incidents of corruption. A small number of instances of fraud committed by employees or business partners of Group companies were otherwise detected and managed. The actions taken in response to these instances were mainly dismissal, the adoption of disciplinary measures or the termination of contracts, depending on the party involved (employee/business partner) and the severity of the event.

With regard to content, in the Code particular attention is paid to the promotion of diversity and inclusion, in the belief that dialogue and cooperation between people with different cultures, skills, perspectives and backgrounds are key elements to ensure the growth of enterprise and innovation.

In support of the relevant principles of the UN Global Compact initiative, we also reiterate our commitment to promoting and ensuring respect for the fundamental human and labour rights in all our spheres of influence and we expressly reaffirm our rejection of all forms of corruption, including the payment of bribes and extortion.

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