Ethics at the heart

Code of Conduct We want all of our people to carry out their daily activities and to interact among themselves and with others according to values, expectations and ethical principles that we have shared in our Code of Conduct. This document represents our guide for acting correctly: it helps us make consistent choices and enables us to continue to work in an environment in which we can take honesty, transparency and impartiality for granted.

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We ask our managers to act as role models for the Code and to make sure their colleagues feel free to ask if a certain form of behaviour or commercial proposal is in line with our values and the principles of our Code.

Everyone is invited to express their preoccupations or to ask for further information on any aspect of our Code. We have made channels of communication available at both local and Group level for people that want to raise any doubts they may have - also anonymously, where permitted by the law - on specific types of behaviour in all of the countries in which we operate. Confidentiality is guaranteed and we will show zero tolerance of any form of retaliation.

311 allegations made via our helpline in 2015*

Helpline

Let's talk ethicsWe continue to disseminate our ethical principles internally and to improve people’s understanding of the various issues covered in the Code of Conduct through articles published on the Group and local intranets. Our series of cartoons and articles called Let’s talk ethics was published each month and ended talking about gifts and forms of entertainment in November 2015.

A new series of cartoon videos called Our Code in Brief has been published from July 2015. They are training videos, each lasting 5 minutes, that allow people to go in-depth and improve the understanding of the specific issues covered in our Code.

We also distributed, on a trial basis in some companies during Integrity week, Our Code - My Notebook, a notebook that employees can use to take their daily notes, which contains our Code at the front and a reminder of the channels they can use to report violations. Given the success of the pilot project, the notebook was included in the welcome pack for new hires.

Integrity week

In the first week of November 2015 we launched Integrity week, a global campaign with initiatives aimed at acquainting people with our Code. As well as online campaigns for the entire Group, every country carried out its own local initiative (meetings at the cafe, signage, training videos etc.). Integrity week was also a chance to highlight the risks of conflicts of interest or corruption connected with the exchange of gifts or forms of entertainment (e.g. vouchers, discounts or special conditions and invitations to work lunches, work do’s and sporting events). We abide by the principle that no gift must be offered or accepted with the intention or expectation of obtaining or retaining business, or a business advantage, or in exchange for favours or benefits of other kinds. For this reason we only allow gifts and forms of entertainment that are of negligible value, appropriate to the circumstances, workrelated, permitted by local laws and in line with standard commercial practices. An information campaign was also launched on this topic with stickers applied to the gifts received by employees in December warning them to verify that the contents were compliant with company regulations. As regards relations with public officers, we have specific provisions according to which the authorisation of a Compliance Officer is required for any gift or form of entertainment.

The Code of Conduct also covers money laundering and the financing of terrorism, emerging priorities all over the world. We are also committed to this international effort. We want to protect our Group from potential financial losses and damage to our reputation, as well as our future. We have adopted a Group Anti-Money Laundering and Anti-terrorism Policy and a Policy on International Sanctions, which define minimum standards of conduct that our companies must abide by and which acknowledge the principles of European and international regulations. We have also implemented automatic tools in all our companies - where applicable - for anti-terrorism screening activities in order to prevent the development of relationships with people on international terrorism lists or any type of payment that could contribute to financing terrorist activities. Finally, we have defined a Group Compliance Program containing the minimum standards of control for the mitigation of risks related to money laundering, the financing of terrorism and the violation of international sanctions, which will be adopted by all of the Group’s insurance companies in 2016.

Sales network One fairly widespread practice in the insurance business is fraud, that is, any intentional illegal act, carried out directly or via third parties, by internal (employees or intermediaries) or external parties (trusted parties such as assessors or forensic pathologists, clients, injured parties or any other third party), with the aim of making an unfair profit, for oneself or for others, to the detriment of insurance companies.
We therefore strive to suppress all An assistance that
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activities that may be defined as fraudulent, working in accordance with the law and internal regulations but also the highest ethical standards, promoting the spread of a culture of legality and moral integrity and adopting the most suitable organisational and operating methods.

49,358 employees that have so far completed the Code of Conduct course

We believe that it is fundamental to train and raise the awareness of our people in relation to the issues covered in our Code of Conduct. All employees must take the introductory e-learning course to the Code of Conduct which lasts about an hour. From 2016 those that took it more than a year ago will have to take an update course. In addition, in 2016 there will be a course for managers on becoming behavioural role models with regard to the Code.

We are completing the preparations for a specific training course to be held in 2016 for employees that work in at-risk areas, such as those that manage relations with suppliers for the procurement of goods and services, in order to improve their understanding of the standards of behaviour that we demand, particularly with regard to conflicts of interest, corruption and the treatment of confidential information.

483 employees working in at-risk areas who have signed the specific code of conduct

In the meantime, this category of employees has viewed and signed their specific code of conduct

We also provide suitable and continuous training to employees who are more likely to come into contact with the corrupt practices and phenomena that can be seen in the insurance sector. The objective is to provide them with the necessary information to identify and manage activities that are potentially connected with fraud, money laundering and the financing of terrorism. As such, in 2015 we organised a number of workshops dedicated to the fight against terrorism which were attended by the compliance departments of the companies of Central and Eastern Europe and the countries belonging to EMEA, Asia and the Americas, and supported by the global compliance departments through the preparation and sharing of materials and onsite visits.

** of which 72 have been found to be valid so far leading to the adoption of disciplinary measures, dismissal or the termination of contracts, depending on the party involved (employee/business partner) and the severity of the event

*A small number of instances of fraud committed by employees or business partners of Group companies were detected and managed in different ways