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 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.

The full meaning of compliance is not simply adhering to legal provisions, regulatory requirements and internal rules (in particular, those of the Code of Conduct), but also extends to making decisions and deciding on activities on this basis. Compliance is therefore a basis for initiating and conducting business transactions, a platform for realising integrity, and a key element in the business processes.

Each individual staff member at Munich Re is responsible for compliance. On the basis of the Code of Conduct, all staff undertake to act in an ethical and reliable manner. In doing so, they should avoid doing anything that might harm Munich Re, and take business decisions in compliance with legal provisions, supervisory regulations and internal rules. Managers have a special responsibility to integrate compliance as an inherent component into the business processes. They have a role model function for their staff and the obligation to ensure that all actions within their area of responsibility comply with laws and statutes and internal guidelines.

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.

In the primary insurance sector, ERGO is taking a progressive approach: On 1 July 2013, with the aim of establishing a clear business foundation for cooperation with insurance brokers, the ERGO insurance group was one of the first companies to commit to the GDV Code of Conduct for sales. This voluntary commitment applies to all operational German subsidiaries that sell insurance products with the aim of ensuring the high quality of client consulting. The appropriate implementation of principles and measures to satisfy regulations was confirmed in June 2014 by an external auditor.

Expansion of compliance management and Group-wide application
The Munich Re compliance management system is the methodical framework for the structured implementation of early warning, risk control, consulting and supervision functions, as well as for the monitoring of background legal conditions. It consists of seven tools: compliance culture and strategy, compliance risk management, organisation and processes, consulting, communication and training, compliance reporting, monitoring and control.

We have developed a modular compliance approach to allow for local conditions in the different Group companies. For example, a small company with low risk exposure only needs to implement minimum compliance standards, whereas a large company with high risk exposure must effectively implement comprehensive CMS. This approach was introduced in the Group in 2015.

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. The Munich Re Compliance Whistleblowing Portal has been open for all staff or external whistleblowers since mid-November 2013. 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 between economic, ecological and social aspects in our procurement. In this way, we extend our commitment to abide by the Global Compact in dealings with our business partners too. (You can find more on the topic of "Sustainable supply chain management" here.)



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