Compliance – Binding rules of conduct for the Group

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Binding rules of conduct for the Group

Compliance with applicable laws and internal rules and principles (compliance) is binding for all employees of Munich Re. To ensure compliant conduct, we have created Group-wide guidelines and suitable information and documentation systems as control measures.

Global Compact as our guideline
Since 2007, Munich Re Group has been committed to 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 annual Communication on Progress (COP) is integrated in our Corporate Responsibility portal.

Group-wide Code of Conduct
The central guideline for 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 is regularly reviewed and expanded as needed. In 2013, for example, we anchored the understanding of values conveyed in the Global Compact by expressly referring to the ten principles in the introduction to our Code of Conduct. In 2012, we introduced rules of conduct to ensure that our interaction with clients is fair. Our objectives in doing so were to ensure that we meet legal requirements and to define a uniform Munich Re position with regard to "ethical walls" situations. The code applies to all employees in reinsurance units who make or can influence business decisions or who have access to confidential information.

Expanding compliance management
We continually refine our compliance systems in order to ensure comprehensive, efficient value management. One key component in this regard is giving our employees training in dealing with compliance-related issues. Our annual Compliance Awareness Survey, a structured and comprehensive survey among our employees, helps us to identify potential areas of improvement and derive appropriate measures. The high level of participation across all divisions and hierarchies is a clear indication of how important our staff members consider the subject of corporate compliance to be. We are pleased that, according to the survey, our managers enjoy great confidence in matters of compliance; at the same time, we see a need to further expand our communication and training measures in connection with this multifaceted topic.

Direct channels of communication and the protection of anonymity
Munich Re has a Group-wide system for reporting violations of rules and laws. This system enables the Group Chief Compliance Officer to quickly report potential violations to the Board of Management. This officer is the first contact for all questions and assists the Board of Management in developing and implementing organisational measures. Staff members can report infringements and violations to the Group Chief Compliance Officer, their direct supervisor or Group Audit. The compliance system is complemented by an external, independent ombudsman.

To strengthen the compliance system even further, the Board of Management decided to make available an additional channel. Since mid-November 2013, Munich Re has also maintained a Compliance Whistleblowing Portal where employees and others can provide tips and information. This portal can be used to anonymously report serious violations involving fraud, insider trading, anti-trust and data protection infringements and punishable reputational risks.

Sustainable procurement
We also strive to achieve a balance of economic, ecological and social aspects in our procurement. The reinsurance group's purchasing guideline 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 are extending the commitments of the Global Compact to our business partners as well.

The clause that is gradually to be incorporated in contracts throughout the group reads: "Munich Re is a member of the UN Global Compact initiative. Munich Re has thus committed itself to protecting human rights, preventing forced 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 that these principles are violated, Munich Re reserves the right to extraordinarily terminate the relevant contract(s) for good cause."

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