Binding rules of conduct for the Group
Compliance with applicable laws and internal rules and principles is binding for all Munich Re (Group) staff. To ensure compliant conduct, we have created Group-wide rules, minimum compliance requirements and suitable information and documentation systems as prevention and monitoring measures.
Each individual employee at Munich Re (Group) is responsible for compliance. On the basis of our Code of Conduct and additional self-commitments for responsible behaviour, all staff 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 staff receive the Code of Conduct and additional self-commitments for responsible behaviour. Also, an e-learning programme has been developed and made available to for all staff.
For us, the full meaning of compliance is not simply adhering to the letter of the law, regulatory requirements and internal rules (in particular, those of the Code of Conduct), but also extends to making decisions and acting in the spirit of compliance. Compliance is therefore a basis for initiating and conducting business transactions, a platform for realising integrity, and a key element in our business processes.
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 was one of the first companies to commit to the Code of Conduct for selling insurance products which was initiated by the German Insurance Association (GDV). This voluntary commitment applies to all operational German ERGO 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 by an external auditor.
Group-wide Compliance Management System (CMS)
The compliance function is responsible for specifying the necessary organisational measures for compliance by Munich Re (Group), top and senior management, as well as employees, including monitoring such compliance. For this purpose, the compliance function has set up an appropriate compliance organisation across the Group, which is tailored to the structure, business activities, risks and particularities of Munich Re (Group)’s business model. The Munich Re (Group) Compliance Management System (CMS) is the methodical framework for the structured implementation of early warning, risk control, advisory and monitoring functions Group-wide:
- The early-warning system evaluates the potential impact of any material emerging legal changes on the operations on Munich Re (Group). Therefore, Munich Re (Group) companies regularly report on changes in their legal environment (legal change risk).
- Risk control duties include the identification, assessment, continuous observing, managing, and reporting of compliance risks within Munich Re (Group).
- Monitoring refers to regularly reviewing the adherence to applicable external and internal requirements in Munich Re (Group).
- Advisory means that the Munich Re (Group) compliance function and the Group-wide compliance organisation support and train top and senior management, managers, and employees on how to adequately prevent and respond to violations of external and internal requirements or reputation damaging behaviour.
Our CMS is designed to identify key compliance risks and thus prevent the violation of external and internal requirements and behaviour that puts Munich Re (Group)'s reputation at risk (prevention), to investigate any potential violations that may occur despite appropriate measures (detection), and to sanction and terminate breaches (response). The CMS is based on external standards and has been carefully adjusted to Munich Re (Group) characteristics. It consists of the following seven instruments:
Direct channels of communication and whistleblower anonymity
Munich Re (Group) has a Group-wide system for reporting violations of rules and laws. This system enables the Group Chief Compliance Officer (GCCO) to quickly report potential violations to the Board of Management. The GCCO is the first contact for all compliance questions and assists the Board of Management in developing and implementing organisational measures. Staff members can report infringements and violations to Compliance, their line manager, or to Internal Audit. In addition, an external, independent ombudsman may be contacted. A further whistleblowing channel is available to make the CMS even more robust: A Compliance Whistleblowing Portal is available to all staff and third parties for reporting compliance violations. Information can be provided anonymously or by using your name. If legally possible, anonymity is guaranteed
GRI: G4-27; G4-56; G4-57; G4-58; G4-DMA-Procurement Principles; G4-EC9; G4-EN32; G4-EN33; G4-DMA-Supplier Assessment; G4-DMA-Human Rights; G4-HR2; G4-HR3; G4-HR4; G4-HR5; G4-HR6; G4-HR7; G4-HR8; G4-PR6