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Sanctions
Observance of applicable sanctions regulations plays a central role for us on account of our international orientation. We have enshrined the requirement for compliance with relevant sanctions provisions in our 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 hence with whom no business may be transacted. In the year under review additional international 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 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.
The sanctions screening software identified one legal entity in the Group's data inventory in the year under review that is the subject of an assets freeze. In addition, another legal entity was identified in the Group's data inventory that was indirectly controlled by a so-called "listed entity". Steps were taken to prevent both the renewal of the treaties in question and a repetition of such occurrences. These incidents demonstrate the effectiveness of the screening process.