Compliance

VIG Compliance Organisation

Goals and structure of the compliance organisation

The goal of the group-wide compliance management system of 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 “VIG Compliance (incl. AML)” department, established in 2015 holds the compliance function for VIG Holding as an individual company and the Group , and deals, inter alia, with matters related to insurance (supervisory) law (incl. Solvency II), issuer compliance, integrity management, confidentiality and data protection, prevention of money laundering and terrorist financing, FATCA as well as sanctions and embargoes. The department sets various minimum compliance standards which apply to both VIG Holding and the Group and which shall be implemented by the Group companies.

The Head of Compliance (incl. AML) reports directly to the Managing Board. The function is organizationally 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 at both Holding and Group level. The Head of Compliance (incl. AML) 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, who are responsible for compliance with the relevant provisions in their areas or companies. The Head of Compliance (incl. AML) coordinates and supports their activities and holds a monitoring function.

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 guardrails for e.g. compliance with laws and regulations on human rights, anti-discrimination, prevention of conflicts of interest, bribery and corruption, confidentiality and data protection, prevention of market abuse, fair competition and environmental and social responsibility, and is available on the VIG Groupnet.

At the top level, the VIG Managing Board is responsible for the application of the Code of Business Ethics. The heads of department bear the responsibility for compliance with the rules in their respective areas of responsibility. At the level of the Group companies, the respective local management board is responsible for compliance with the Code of Business Ethics. 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 regulations, VIG Internal Audit monitors compliance (especially issues related to bribery and corruption) with these values and regulations 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

VIG Compliance (incl. AML) is available at any time as point of contact for answering specific questions and delimiting doubtful questions.

Handling reports on bribery and corruption

The reporting channels established by VIG in accordance with applicable laws are available for reporting information related to bribery and corruption. Details on whistleblowing can be found here.

Regardless of how whistleblowing reports are received by the VIG Compliance (including AML), they are processed with diligent care and in compliance with the applicable legal provisions. Both the whistleblowers and the accused persons are subject to the protective regulations on confidentiality and data protection. The facts, processes and persons involved are examined in detail until every suspicion has been completely dispelled and all inconsistencies have been clarified.