Binding rules of conduct for the Group

Each individual employee at Munich Re (Group) is responsible for compliance. On the basis of the Munich Re (Group) Code of Conduct and additional (self-)commitments for responsible behaviour, all employees are obliged to act in an ethical and reliable manner. In doing so, they are to avoid any activity that might harm Munich Re (Group), and are to take business decisions in compliance with legal provisions, supervisory regulations and internal rules. Our managers have a special responsibility to integrate compliance as a fundamental 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 the law, statutes and internal rules. All employees receive the Code of Conduct and additional (self-)commitments for responsible behaviour, and complete an e-learning program on the Code of Conduct.

ERGO attaches the greatest importance to high-quality customer advice. This is reflected in the fact that ERGO joined the Code of Conduct of the German Insurance Association (GDV) for the distribution of insurance products back in 2012. This code commits the participating insurers and their agents not only to high standards in terms of advice and mediation, but also to having their compliance regularly assessed by an independent auditor. KPMG has confirmed ERGO's effectiveness in implementing the contents of the Code for the third time.

Munich Re (Group) has developed a Compliance Management System (CMS) that is based on external standards and has been carefully tailored to Munich Re (Group) characteristics. The CMS is the methodological framework for the structured implementation of the early warning, risk control, advisory, and monitoring functions within Munich Re (Group).

The CMS is designed

• to prevent the violation of external and internal requirements by implementing norms and regulations, communication, training and advising of management and employees (Prevent);
• to manage and monitor material compliance risks,  and to investigate and remediate any potential violations that may occur despite appropriate measures (Discover);
• to regularly report about and to continuously improve the CMS (Respond).

This approach is illustrated by the following graph:

The scope and type of implementation of the compliance activities in an entity of Munich Re (Group) are based on its risk profile.

Munich Re (Group) has a Group-wide system for reporting violations of rules and laws. This system enables quick reporting on this to the responsible management body. Employees can report plausible indications on possible violations to Group Compliance and Legal or their direct manager. In addition, an external, independent ombudsman may be contacted or the Compliance Whistleblowing Portal. This is available to all employees and third parties for reporting compliance violations (also anonymously).