Preventing Financial Crime and Sanctions Violations at Swiss Re

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.

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: "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.

Examples of practices that are prohibited in the "Global Standard on Anti-Bribery and Corruption" include:

• facilitation payments (an unauthorised payment to a public official to facilitate a transaction eg to expedite a process or grant a license);
• giving or receiving cash gifts or cash equivalent gifts (eg gift cards); or
• giving or receiving any advantage which could improperly influence, or be perceived to improperly influence, a business decision (eg giving or receiving an unauthorized commission - kickback - to an individual).

How does the Compliance Risk Framework deal with preventing bribery and corruption?

The Anti-Bribery and Corruption Framework is structured around the following four pillars:

(i) Policies, standards and processes

• Policies and standards: Our "Global Policy on Financial Crime and Sanctions" and "Global Standard on Anti-Bribery and Corruption" set out our overarching principles, requirements and processes for preventing bribery and corruption. These are complemented as needed with the development and roll-out of related documents. Our policies comply with applicable laws and regulations, including the requirements in the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act.
• Controls and Processes: We have defined controls and processes to address bribery and corruption risks. We perform a Compliance Risk Assessment which identifies specific residual risks that require an enhancement to the Anti-Bribery and Corruption Framework or controls. The receipt and provision of gifts and hospitality subject to the "Global Standard on Anti-Bribery and Corruption", are documented in line with the requirements in our "Global Standard on Records Management". The performance of due diligence on business partners (including clients, customers, joint ventures, and other partners across all Swiss Re Group reinsurance, direct insurance and asset management operations) assesses if any bribery and corruption risk factors are present and perform enhanced due diligence where one or more risk factors are present which is updated regularly. The four key risk factors are: unusual payments or requests for payment, unusual or unexpected behaviour, lack of transparency, and public official influence.

(ii) Training and awareness

• Mandatory training: Employees are required to provide an acknowledgement of global compliance policies including the Code of Conduct and the "Global Standard on Anti-Bribery and Corruption", on an annual basis. New employees are required to complete compulsory e-learnings within 3 months of joining. Specific Anti-Bribery and Corruption training is rolled out on a global basis at least every 3 years or when material changes have taken place. As with other Compliance training, Anti-bribery and Corruption training features real cases and business scenarios to demonstrate how controls protect against bribery and corruption risks in practice. There is a defined escalation process with disciplinary action as a consequence of non-completion.
• 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 eg e-learnings, recorded web-based conferences and face-to-face training.
• Third party training: Contractors and certain partners and suppliers are assigned new employee onboarding eLearnings and are required to undergo training  on a risk-based assessment and on a frequency determined by the risks associated with the specific third party.
• Communication and awareness programmes: Periodic, risk-based awareness and communication efforts supplements the training initiatives.

(iii) Tools and technology

We have deployed the following tools within the Anti-Bribery and Corruption Framework:

• a mandatory Gifts and Hospitality Register to track and require review of gifts, hospitality, sponsorships, charitable contributions and political contributions above specified thresholds;
• dashboards to provide information for reporting and analytical purposes; and
• MyCompliance, an internal portal for all compliance-related information tailored to each employee's needs.

(iv) Assurance, investigations and monitoring

• Assurance: A designated compliance assurance team performs compliance monitoring activities across the Compliance Risk Frameworks, including the Anti-Bribery and Corruption Framework. All assurance activities are planned by Compliance Assurance and subsequently presented to, and approved by the Group Executive Committee and, at board level, the Group Audit Committee and then reviewed annually following a risk-based assessment.
• Investigations: Investigations into reported alleged misconduct are a key component of the Compliance programme. Disciplinary actions eg warnings, suspension or termination, and other consequences eg process enhancements or training, are identified and centrally logged.
• As a result of assurance activities and investigation, the principles of root cause analysis are applied in order to understand where improvements can be made and inform future framework strengthening activities.
• Monitoring: The Compliance Assurance team monitors activities including certain issues, incidents, management actions and investigations. This occurs by way of checking the efficacy of automated controls and regular reports are submitted to the applicable management teams.
   
• The investigation process and overall framework are reviewed by Swiss Re's internal and external auditors.

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 Code of Conduct. 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; and
• internal and independent reviews and audits to test the design and effectiveness of our AML framework.

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 is committed to preventing, detecting and responding to fraud. We ensure the highest standards of honesty and integrity and have 'zero tolerance' for any form of fraud. Together with the "Global Policy on Financial Crime and Sanctions", the "Global Standard on Anti-Fraud" sets out how to prevent, detect and respond to fraudulent activities in order to protect Swiss Re and its employees against losses, legal and reputational damage, substantial fines and/or other disciplinary actions as a result of fraudulent activities.

We define fraud as any wrongdoing that involves intentional deception or misrepresentation for personal gain. Fraud can be internal (committed by employees) or external (committed by a party outside of Swiss Re) or a combination of internal and external.

Swiss Re has implemented a Fraud Compliance Framework and our approach is also defined in the Code of Conduct.