Preventing Bribery and Corruption at Swiss Re
Swiss Re is a leading wholesale provider of reinsurance, insurance and other insurance-based forms of risk transfer. We operate in over 80 offices located in more than 30 countries. As a global reinsurance and insurance provider, we have a strong commitment to preventing criminal and unethical behaviour. We have instituted a global bribery and corruption compliance framework in order to give effect to our prohibition on all forms of bribery and corruption.
What is our position on preventing bribery and corruption?
Swiss Re's commitment to preventing bribery and corruption is stated in the Swiss Re Code of Conduct (Code): "We conduct business fairly without accepting or offering benefits intended to improperly influence decision-making".
In short, we prohibit all forms of bribery or corruption.
No employee may directly or indirectly offer or grant bribes to anyone to influence any action. "Anyone" includes public officials and business partners. Employees must avoid even the appearance of bad faith or impropriety.
What do we mean by bribery and corruption?
Swiss Re defines bribery and corruption (bribery) as receiving, accepting or offering a financial or non-financial advantage (for example, gifts or hospitality) by, or to, any person in order to influence them, or another, to perform a duty improperly, or to reward that person for having already done so.
Examples of bribery include: facilitation payments (an unauthorised payment to a public official to facilitate a transaction e.g. to expedite a process or grant a licence); kickbacks (an unauthorised commission to an individual); giving or receiving cash payments or the equivalent (e.g. gift cards); or giving or receiving any advantage which could improperly influence, or be perceived to improperly influence, a business decision.
How do we implement this approach to preventing bribery and corruption?
Key Compliance risks are addressed throughout the Compliance Framework, which includes policies, standards, training, assurance activities, enabling advice and tools. One of these key risks is bribery and corruption.
Who has responsibility for the Compliance Framework?
Operationally, the Compliance function, led by the Chief Compliance Officer, has primary responsibility for the Compliance Framework and the management of risks, policy governance, assurance and awareness.
Executive responsibility for the Compliance function and Compliance Framework lies with the Group Audit Committee (GAC), Group Executive Committee (GEC) and Board of Directors, in accordance with the Corporate Governance Guidelines.
Finally, Group Internal Audit (GIA) has responsibility for providing an independent assurance function and performs annual audit activities in relation to the Compliance Framework.
Who does the Compliance Framework apply to?
The Compliance Framework applies to every full or part time Swiss Re employee of a company within the Swiss Re Group, including all affiliates worldwide. It also applies to everyone working for or on behalf of Swiss Re, including, for example, all board members, managers, employees, trainees, freelancers, contingent workers and temporary staff and others working in equivalent positions.
In addition, the Compliance Framework applies to our business partners including contractors, outsourced providers and agents; and all entities that Swiss Re controls worldwide.
How does the Compliance Framework deal with preventing bribery and corruption?
As a key risk, bribery and corruption has its own framework that is structured around the following four pillars:
Policy standards and processes
- Policies and standards: Our "Global Policy on Financial Crime" and "Global Standard on Anti-Bribery and Corruption" set out our overarching principles and compliance processes. These are complemented with the development and roll-out of related documents and guidelines. These policies are aligned with the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.
- Processes: We have defined processes across the lifecycle of the compliance function, each of which has an element applicable to the bribery and corruption risk. The key process is the Risk Assessment which identifies the specific residual risks that we may need to address within our bribery and corruption programme. Further, all approvals, rejections and decisions subject to the "Global Standard on Bribery and Corruption", including any supplementary documentation, are documented in line with the requirements in our "Global Standard on Records Management".
Tools and technology
We have deployed the following tools to better manage the bribery and corruption risk:
- a Gifts and Hospitality Register to track gifts, hospitality, sponsorships, charitable contributions and political contributions above specified thresholds,
- dashboards to provide information for reporting purposes,
- MyCompliance, an internal portal for all compliance-related information tailored to each employee's needs, and
- a Conflicts of Interest Register to record personal conflicts of interest.
Assurance, investigations and reporting
- Assurance: A designated compliance assurance team performs compliance risk reviews and monitoring activities across the Compliance Framework, including bribery and corruption. All assurance activities are planned, presented and approved by the GEC and, at board level, the GAC and then reviewed annually following a risk-based assessment.
- Investigations: Investigations into reported alleged wrongdoing are a key component of the compliance programme. Disciplinary actions e.g. warnings, suspension or termination, and other improvements e.g. process, guidelines or training, are identified and centrally logged.
- Reporting: The Compliance Assurance team monitors activities including regulatory trends, issues, incidents, management actions and investigations.
Training and awareness
- Mandatory training: Employees are required to provide an acknowledgement of the Code, including bribery and corruption provisions, on an annual basis and complete mandatory compliance e-learning sessions. New employees are required to complete compulsory e-learnings within 3 months of joining. There is a defined escalation process with disciplinary action as a consequence of non-completion. A key metric in confirming the successful application of the framework is the written acknowledgment from individuals confirming that they have received the minimum mandatory training.
- Targeted training: Compliance training on specific topics is delivered across the globe to business units on a systematic and risk-based approach using different methods e.g. global e-learnings, recorded web-based conferences and face-to-face training.
- Communication and awareness programmes: Led by the Compliance team, a programme of policy awareness initiatives supplements the targeted training and is implemented on a project basis.
Our approach to other financial crime
In accordance with our Code of Conduct, preventing Bribery and Corruption is not the only pillar in our approach to combatting Financial Crime. We also have compliance frameworks dealing with International Trade Controls (ITC) (Sanctions), Conflicts of Interest, Fraud and Anti-Money Laundering (AML). These frameworks follow a similar approach to the one outlined here. To learn more about AML and ITC frameworks see below.
Reporting any suspected bribery or corruption incidents
Swiss Re strives to foster a culture of openness, trust, and transparency. In furtherance of this goal, we encourage the reporting of suspected misconduct to: line managers, HR, Compliance or via the Whistleblowing Hotline where reports may be made anonymously (where legally permitted). This includes reporting breaches of the requirements of our "Global Standard on Bribery and Corruption".
Swiss Re is strongly committed to prevent the use of its operations for money laundering or any activity which facilitates money laundering, the funding of terrorist or criminal activities. Accordingly, Swiss Re complies with all applicable laws and regulations designed to combat such activities.
Swiss Re has implemented a group-wide anti-money laundering (AML) framework in line with the recommendations of the Financial Action Task Force (FATF), to:
- Ensure that the legal and regulatory requirements of various jurisdictions are met where it is operating and
- Manage and mitigate the risk of Swiss Re being involved in money laundering and terrorist financing.
The principles of our AML framework are defined in our Group Code of Conduct, which has been approved by the Board of Directors and the Executive Committee.
In addition, Swiss Re has both global and local AML and International Trade Controls and Economic Sanctions policies, standards, and procedures (including screening processes) in place.
In particular, Swiss Re has:
- Risk-based Counterparty Due-Diligence (including screening) requirements;
- Risk-based transaction monitoring;
- Screening against relevant watchlists;
- Risk-based AML training for employees;
- Designated group and regional money laundering reporting officers and a requirement that all employees report illegal, suspicious or unusual activity to their money laundering reporting officer;
- A process to report money laundering and terrorist financing suspicions to relevant authorities;
- Record-keeping and retention requirements;
- Internal and independent reviews and audits to test the design and effectiveness of our AML framework; and
- A whistleblowing hotline for anonymous reporting.
Swiss Re adheres to ITC laws and regulations applicable to Swiss Re entities and employees. Swiss Re also has policies and procedures that may be stricter than applicable laws and regulations to ensure certain business activities comply globally with sanctions laws, rules, and regulations imposed by the United Nations, United States, European Union, United Kingdom, Switzerland and potentially other country-specific or international sanctions.
Swiss Re has implemented a Group-wide ITC compliance framework and our approach is also defined in the company's Code of Conduct, which has been approved by the Board of Directors and the Executive Committee.