The individual rules of the VIG Code of Business Ethics
Compliance with legal, regulatory and internal provisions ("Compliance")
In our business environment we refuse to getting involved in any illegal practices and do not approve any illegal actions. In all aspects of the COBE we admit to act in compliance with regulations and legal provisions of all countries we operate in. Moreover, we comply with obligations which have been adopted on a voluntary basis, with internal standards as well as commonly accepted ethical standards. We avoid any involvement in activities whose evident intention is to evade any such provisions or standards.
In addition to the local legal provisions, local leaflets or guidelines regarding certain areas of concern will be issued to employees which will either inform about provisions or will determine the correct behaviour in certain situations. Each recipient of such leaflets or guidelines are called to comply with the rules set forth therein.
Furthermore, our employees must refrain from all activities which may lead to the involvement of VIG or its staff in unlawful behaviour.
Protection of human rights
We support and respect the protection of international human rights in our business practice; we are against forced or child labour.
Non-discrimination and manners
We respect the cultures and traditions of the various countries and markets in which we offer our insurance services.
We do not tolerate any kind of discrimination. We are committed to promoting equal opportunities with regard to the employment and promotion of staff, regardless of their faith, religion, sex, beliefs, ethnicity, nationality, sexual orientation, age, skin colour, disability or civil status.
We do not condone sexual harassment or bullying and always strive to treat each other in an appreciative and positive manner.
We deal with business cases and concerns of costumers in a correct, competent, friendly and timely manner.
Our relationships to business partners and authorities distinguish themselves through mutual, respectful and reliable cooperation. We are open to communication and cooperation both at national and international level.
Protection of company property
Generally, company property and resources shall only be used for professional purposes and in accordance with internal regulations. We are committed to treat company property, such as operational equipment, operational facilities as well as intangible goods (e.g. intellectual property including software licenses) with care and to protect them against abuse, loss or theft.
Prevention of corruption and bribery
We oppose all forms of corruption and bribery.
Corruption is the misuse of authority for the private gain of individuals, whether through active or passive conduct, as a recipient or a provider.
For employees of VIG any kind of corruption is forbidden; especially the following rules apply:
VIG employees are not allowed to accept gifts or invitations nor to make any gifts or invitations whose value exceeds the legal frameworks or the local standards and/or which are made with the intention of gaining an improper advantage.
Secondary employments of VIG employees with competitors of VIG are prohibited. A Group company may only permit their employees to take on secondary employment with any customers, suppliers or other business partners of VIG if and insofar as this employment may not give rise to corruption or bribery.
Confidentiality and data protection
Confidential Information made available to us by clients, business partners and employees during the course of business activities is subject to confidential treatment and an obligation to maintain secrecy on the part of employees of VIG.
We are obliged to observe local data protection regulations. We will protect personal data provided by clients, business partners and employees from unauthorized access by third parties and will only pass on such information to employees where it is required for the fulfilling of their duties (“need-to-know”- principle). Personal data is solely obtained, processed and used to the extent necessary and for the intended purpose.
Prevention of market abuse
Inside information regarding issuers or their financial instruments which are listed at regulated or non-regulated markets (like multilateral or organized trading facilities) may have significant influence on the price of the respective financial instruments when being made public. Market abuse jeopardizes the functioning of capital markets and is subject to administrative and criminal penalties.
According to the compliance regulations, employees of VIG who possess inside information are prohibited from dealing with the respective financial instruments (directly or indirectly, for their own account or the account of a third party) by using the inside information or from making recommendation to others regarding the financial instruments concerned. Additionally inside information may not be passed on or otherwise made available to third parties.
Prevention of money laundering and the financing of terrorism
We support international efforts to prevent the abuse of financial systems for money laundering purposes and the financing of terrorist activities. In order to aid the prevention of and to participate in the tracing of such abuse, we are committed to obtaining reliable information about the identity of our clients in terms of the ‘Know your customer’ principle in all countries which we operate in. We pledge to carefully check and, if necessary, to reject insurance business that appears to be unlawful.
Protection of the Environment
The basis of all our actions is a responsible handling of the environment. We are committed to ensuring environmental protection and sustainable economic growth. Acting in an environmentally friendly manner is an active element of our corporate culture. Careful use of resources is an important aspect of our activities and we observe all applicable environmental regulations and corporate environmental standards.
We pledge to take consideration of the effects of our actions on the environment and to pursue our tasks in compliance with the principle of sustainability.
Contact in the event of ambiguities / malpractice
In the event of problems, uncertainty or if behaviour not compliant with the COBE has been observed, all employees can contact their manager or the nominated compliance officer or compliance responsible person at the respective Group Company, in complete confidence and without this leading to any disadvantages for the employee.