Sustainability Report 2015
Sanctions
Observance of applicable sanctions plays a central role on account of Hannover Re's international orientation. Hannover Re has enshrined the requirement for compliance with sanction provisions applicable to the company in its Code of Conduct and Underwriting Guidelines. In addition, a Sanctions Screening Guideline is in place, stipulating when members of staff must perform sanctions screening with respect to the initiation of contracts and/or the payment of claims. A software-supported check continuously verifies whether the company's data inventories include the names of persons who are subject to sanctions and with whom no business may be transacted. In the year under review additional Local Offices were connected to this software-based screening tool. If the software alerts the user to any names, the reported alerts are investigated in a two-step process. If actual matches are determined between the company's data inventory and a relevant list, defined processes are followed in order to prevent contract formation or the payment of funds to listed individuals and the monies in question are frozen. The training given to new members of staff also includes a section on sanctions, with the result that all new employees at Home Office in Hannover receive basic instruction in sanctions law. Underwriters and claims managers receive additional training in the use of the screening software as well as in the scenarios in which a sanctions check must be made. Further training activities are offered as needed and on an individual basis for affected departments. Each working day staff in Group Legal check the Official Journal of the European Union for changes in sanctions law on the EU level and publicise relevant changes Group-wide without delay.
Our Compliance Management System for sanctions was reviewed in the year under review by an external firm of auditors and consultants. No significant shortcomings were identified in this context.
The sanctions screening software identified one individual in the Group's data inventory in the year under review who is the subject of an assets freeze. An assets freeze was imposed on this individual in October 2015 and this immediately triggered an alert by the software. The policy was suspended at once and the incident was reported to the responsible authority. This incident demonstrates the effectiveness of the screening process.