Reporting Misconduct (Whistleblowing) at Swiss Re

Swiss Re strives to foster an environment where everyone feels comfortable speaking up. We encourage anyone to report incidents if they suspect someone inside, or connected with, Swiss Re is acting in a manner that could constitute misconduct.

Swiss Re`s Whistleblowing Programme

Swiss Re`s Whistleblowing Programme is designed to enable people to report misconduct securely and confidentially and ensure that the review and investigation of such reports is carried out by competent and authorised persons. The Whistleblowing Programme is underpinned by the "Global Standard on Whistleblowing" which is available in 7 languages (English, French, German, Italian, Chinese, Spanish (Latin America) and Portuguese (Brazilian)) and is regularly reviewed and updated. The Whistleblowing Programme complies with applicable laws and regulations, including Directive (EU) 2019/1937 and is available to all Swiss Re employees, as well as anybody engaged in a work-based relationship with Swiss Re, such as trainees, freelancers, contractors, contingent workers, temporary staff, suppliers, consultants or others working in similar positions.

What is misconduct?

Swiss Re defines misconduct as any illegal or improper act. This includes breaches of the Swiss Re Code of Conduct, a failure to comply with any applicable regulatory requirement and/or activity that appears to be illegal or improper in nature.

How to report misconduct

There are several channels available for reporting suspected of actual misconduct:

  • Internally to the:
    • Investigation Coordination Process team (ICP see "Investigating Reports" below) by e-mailing [email protected];
    • local Compliance contact;
    • local Employee Relations contact; and/or
    • Head of Group Internal Audit (for exceptional circumstances involving errors or misrepresentations in Swiss Re's financial statements or audit reports); and/or
  • Externally to the:
    • Whistleblowing Hotline which permits anonymous reporting, includes translation services into numerous languages, is available worldwide, and allows both phone and written reporting;
    • relevant external competent authority (eg a local regulator); and/or
    • in accordance with any additional local processes relevant to the reporter's location.

Suspected misconduct can be reported orally or in writing. Alternatively, an in-person meeting with any of the above contacts may be requested.

Reviewing and Investigating Reports

If a report is received by one of the channels set out above, the reporter will receive confirmation of receipt within 7 days. Swiss Re will promptly review all reports to determine whether an investigation is warranted. Swiss Re will also refer cases to law enforcement or regulatory authorities if necessary or appropriate, and subject to any confidentiality or privacy concerns.

Where it is determined that an investigation is required, the investigation will be handled by impartial and authorized persons within the relevant Swiss Re function. Generally, this function will be the ICP team (which is managed by Compliance) or Employee Relations (which is managed by HR), in conjunction with delegation to local representatives where applicable. Reporters will, where possible, be provided with feedback in the form of high-level status updates upon request (and in any event within three months of receipt of the report) and notice of investigation closure.

If an investigation determines that someone has committed misconduct in any way, they will be subject to disciplinary and potentially legal action commensurate with the severity and type of misconduct.

Zero tolerance for retaliation

Swiss Re explicitly prohibits any form of actual, threatened or attempted retaliatory action against anyone who, in good faith:

  • reports suspected misconduct with a reasonable belief the information is true;
  • assists with investigations arising from such reports; or
  • is connected with the reporting person and could suffer retaliation as a result such as relatives or colleagues.

Suspected or actual retaliatory action should be reported via one of the channels set out above. Any substantiated breach of this prohibition on retaliation will result in disciplinary and potentially legal action.

Further information about retaliation

Further information about retaliation

We define retaliation as any direct or indirect act or omission which:

  • occurs in a work-related context;
  • is a result of making a report or participating in an investigation of suspected 
    or actual misconduct; and 
  • causes, or may cause, detriment. 

The following is a non-exhaustive list of examples of retaliation:

  • discrimination, disadvantageous or unfair treatment;
  • reputational harm eg social media posts;
  • financial harm eg loss of business or income;
  • unwarranted:
    • termination or suspension of employment (whether permanent or temporary);
    • demotion or withholding band advancement;
    • negative performance review or employment reference;
    • exclusion from meetings, training opportunities or corporate event attendance;
    • change of working conditions or duties without notice (eg location, working hours or wage reduction);
    • failure to renew, or early termination of, a temporary employment contract; or
    • early termination or cancellation of a contract for goods or services;
  • coercion, intimidation, harassment or ostracism;
  • imposition of unwarranted disciplinary measures or reprimand;
  • failure to convert a temporary contract into a permanent contract where there was a legitimate expectation that this would take place;
  • blacklisting within a sector or industry; and/or
  • cancellation of a licence or permit.

Confidentiality, anonymity and personal information

Swiss Re will make every effort to keep all reports, including the identity of the reporter, confidential. Details related to a report will only be disclosed to the extent necessary to investigate the allegations or where disclosure is required in connection with applicable legal, governmental or regulatory proceedings. Reports can be made anonymously, particularly via the Whistleblowing Hotline, however sufficient detail about the misconduct must be provided so that it may be appropriately reviewed. Any personal information received in connection with a report will be processed in accordance with Swiss Re Global Privacy Notice.

Training and Awareness

Every mandatory Compliance training contains information on reporting misconduct, and integrity led activities are rolled out to the whole Swiss Re Group which provide specific training on the Whistleblowing Programme. Regular communication efforts supplement these training initiatives, eg various series dedicated to misconduct awareness have been published globally. Further training and awareness is delivered across the globe to local business units using different methods eg e-learnings, recorded web-based conferences and face-to-face training.

Further Information

For more information on Swiss Re`s Whistleblowing Programme please contact Compliance.