COMPLIANCE

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, 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, integrity management, confidentiality and data protection, prevention of money laundering and terrorist financing, asset management compliance as well as sanctions and embargoes. The area also sets compliance standards aimed at promoting an awareness of compliance in the Group.

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. 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, 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 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 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 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.

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.