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 a 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 into our corporate responsibility portal.
Group-wide code of conduct
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 amended as needed. Based on the code of conduct, we introduced a new guideline for fair, client-focused conduct in 2012. Our aim was to ensure that the legal requirements are met and to define a uniform Munich Re position with regard to "ethical walls" situations. The guideline applies to all employees in the reinsurance units who make business decisions independently or who have access to confidential information.
Expanding compliance management
We are continually refining our » compliance systems in order to ensure comprehensive, efficient value management. A key component in this regard is training our employees in issues relevant to compliance. The annual "Compliance Awareness Survey", a structured and comprehensive survey among our employees, helps us to identify potential areas of improvement and to define specific measures on this basis. The high rate of participation in the 2012 survey across all units and hierarchical levels clearly shows that our employees attach great importance to the topic of compliance. 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 protection of anonymity
Munich Re has a Group-wide reporting system for violations of laws and rules. 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.
At the instigation of the Board of Management, we have established another channel to complement the external independent ombudsman and thus strengthen the compliance system: » Munich Re's Compliance Whistleblowing Portal, available to staff and informants with effect from mid-November 2013. This portal can be used for anonymously reporting serious violations in the areas of fraud, antitrust law and insider trading, or data protection infringements and reputational risks recognised as criminal offences.
ERGO reinforces compliance in its corporate structure
The primary insurer has developed the compliance function into a separate central division reporting directly to the Chairman of the Board of Management since July 2012. 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, transparent requirements for performance bonuses.
In our procurement policy, we also aim to achieve a balance in terms of economic, ecological and social respects. 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 gradually be implemented in the contracts Group-wide, states: “Munich Re is a member of the UN 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.”