VIG Compliance Organisation
VIG compliance organisation
Goals and structure of the compliance organisation
The goal of the group-wide compliance management system of Vienna Insurance Group ("VIG") is to ensure compliance with the legal provisions applicable to VIG and the obligations that it voluntarily assumes, and to promote a culture of integrity to protect the good reputation of the Company.
The “Group Compliance” area established in January 2015 is responsible for compliance activities both in VIG Holding as an individual company and at the group level, and deals, for example, with matters related to insurance law (incl. Solvency II), issuer compliance, anti-corruption, confidentiality and data protection, as well as sanctions and embargoes. The area also sets compliance standards aimed at promoting an awareness of compliance in the VIG group.
The Group Compliance Officer reports directly to the Managing Board. She is organisationally separated from VIG's other key functions, performs her duties independently, and has no operational responsibilities related to VIG's core business activities.
The VIG compliance organisation has a decentralised structure. The Group Compliance Officer works in close coordination with the compliance contacts in VIG Holding (mainly key personnel, area heads and special officers) and local Group company compliance officers, and coordinates communications with them. Compliance-related topics are handled, among other things, during regular Compliance Committee meetings.
Legally compliant and ethical conduct
VIG has zero tolerance for fraud and corruption and explicitly rejects all forms of corruption and bribery. Offering and/or accepting bribes, and all other forms of corruption are strictly forbidden (in both the private and public spheres). VIG requires transparency, integrity and compliance with anti-corruption and bribery laws in all lines of business, and places great importance on legally compliant and ethically correct conduct by all Group companies and their employees. A uniform group-wide Code of Business Ethics applies to all employees, sets down principles for compliance with laws and regulations on anti-discrimination, prevention of bribery and corruption, insider trading, confidentiality, data protection and environmental and social responsibility, and is available on the VIG intranet.
At the top level, the VIG Managing Board is responsible for application of the Code of Business Ethics. The members bear responsibility for compliance with the rules in their areas of responsibility. Employees receive compliance training to learn about compliance-related topics.
Monitoring of compliance with anti-bribery and anti-corruption measures
In addition to training in VIG's values and norms, the Internal Audit department monitors compliance (especially issues related to bribery and corruption) with these values and norms by periodically checking for suspicious conduct and events that suggest unlawful conduct. In addition to routine audits, special event-driven audits are also performed in cases where specific grounds for suspicion make such an audit appear reasonable and necessary.
Point of contact for bribery and corruption issues
The area Group Compliance is a point of contact for concrete issues, and deciding applicability in cases of doubt.
Handling of bribery and corruption reports
Concrete grounds for suspicion can, for example, be based on observations of unusual events and occurrences that differ from prior experience, as well as reports of suspicion of unlawful conduct in the form of bribery or corruption.
It makes no difference how the reports are made – all reports, including anonymous reports, are investigated with great care. The circumstances, events and people involved are investigated carefully until all suspicion has been eliminated and all irregularities have been clarified.
Handling of identified cases of bribery and corruption
If the grounds for suspicion turn out to be justified, rigorous action is taken and appropriate measures are imposed.
VIG Group Compliance Officer - contact details:
Jasmin Schwarz
Schottenring 30
1010 Vienna
e-mail: jasmin.schwarz(at)vig.com