Compliance with laws, regulations and codes
Munich Re has clear objectives and values, including compliance with laws and consequently zero tolerance regarding corruption and other forms of financial crime. A Group-wide Code of Conduct and strict monitoring measures backed up by suitable information and documentation systems help to prevent any infringements of laws or regulations.
» Compliance – i.e. “acting in accordance with applicable laws and internal company directives and principles” (according to the definition in the » German Corporate Governance Code) – is an integral part of Munich Re's corporate strategy.
Code of Conduct with binding rules
Another guiding principle of our actions is our » Code of conduct, which describes our understanding of values and has also been implemented by our subsidiaries. It specifies rules that are binding for all Munich Re staff, and it is regularly reviewed and updated. In 2011, for instance, it was supplemented by the code of conduct for all dealings with brokers and by a guideline prohibiting business with the producers of landmines and cluster bombs. In accordance with Article 7 of the Code of Conduct and the special regulations regarding financial sanctions (available on the intranet), all employees must ensure that their unit and Munich Re adhere to the applicable sanctions and are not wrongfully used for the financing of terrorist organisations, money laundering or other illegal purposes. Staff must therefore check that sufficient information is held on business partners, their background and the purpose and admissibility of any intended transactions before they take place.
Systematically expanding compliance management
To optimise the outcome of this value management, we are constantly refining our compliance measures and conveying our knowledge in face-to-face training and e-learning programmes. In 2011, we added a new module to the Code of Conduct. The fact that we need to enhance our service and further improve communication is also underscored by the Compliance Awareness Survey among our staff. In particular, we are expanding our training on major risks such as corruption and data protection. And our induction course for new staff includes the subject of compliance.
Safe channels of communication and protection of anonymity
In addition to monitoring compliance, Munich Re has introduced a Group-wide system for the reporting of any legal or regulatory infringements. The system allows rapid reporting on infringements via the Compliance Officer to the Board of Management. The Compliance Officer is the contact point for all questions and assists the Board of Management in developing and implementing organisational measures. Employees have the opportunity to report incidents directly to the Compliance Officer or Group Audit. To strengthen the compliance system further, an independent, external » ombudsman has been appointed.
ERGO anchors compliance in its corporate structure
An independent compliance has been set up by the primary insurer, with Stefanie Held – attorney and acknowledged expert – holding the position of Chief Compliance Officer since January 2012. She has an exclusive and direct reporting line to Dr. Torsten Oletzky, Chairman of the Board of Management. In addition, ERGO has supplemented its compliance rules, expanded its code of conduct to include independent agents and tightened up the implementation of these rules and regulations. These include an extensive reporting system and clear requirements for performance premiums.
Global Compact as the central guideline
Munich Re remains committed to the implementation of the ten principles of the United Nations » Global Compact. These represent a worldwide standard and help us to continue to improve our corporate responsibility. The Communication on Progress (COP) is located here on our corporate responsibility portal.
In our procurement policy, we also aim to achieve a balance in terms of economic, ecological and social aspects. The internal purchasing guideline of Munich Re (reinsurance) stipulates that from October 2009 on all newly concluded contracts with suppliers and service providers must include an appropriate corporate responsibility clause. In this way, we extend the commitments of the Global Compact to our business partners as well.
The clause, which will be implemented in the purchasing guidelines further on group level through a graduated scheme formulates: “Munich Re is a member of the UN's Global Compact initiative. Munich Re has thereby committed itself to protecting human rights, preventing forced, compulsory and child labour, promoting environmental protection, and combating corruption. Accordingly, as a prerequisite for cooperation, Munich Re also expects its business partners to comply with the principles laid down in the UN's Global Compact. In the event of breaches of these principles, Munich Re reserves the right to cancel the contractual relationship by way of extraordinary termination for good cause.”