Sustainability Report 2012 - Generali Versicherung AG

In Italy, the Group Anti-money Laundering Policy wasapproved along with the Manual for Anti-money LaunderingProcedures, which defines the operating details for eachindividual company.Lastly, in order to avoid conflicts of interests, in compliancewith the provisions of the Consob Regulation adoptedby means of Resolution no. 17221/2010, Related PartyTransaction Procedures were prepared.Generali Foundation, Vienna, AustriaAnother tool designed to discourage and combat any typeof fraudulent behaviour engaged in by collaborators tothe detriment of the Group is the Internal Fraud policy.The document was issued by Assicurazioni Generali on27 September 2010 and later adopted by all companies ofthe Generali Group.The policy focuses exclusively on internal fraud, that isdefined as an intentional act that is illegally performed byone or more staff members, i.e. employees, regardless oftheir function, classification and/or level as well as other staffmembers to the extent that is consistent with their contracttype, directly or by way of third parties, in order to obtain aprofit for themselves or for others. Such act causes or maycause damage, as well as non-economic damage, to theGroup and/or lack of compliance by the Group, providedthat it is directly or indirectly related to the activities carriedout by the staff members within his/her relationship with theGroup. Therefore, the document outlines a set of principlesand organisational strategies to efficiently and effectivelycombat internal fraud.Guidelines and minimum standards of conduct whichGroup companies must comply with in order to combatmoney laundering and international terrorism financingare contained in the Group Anti-money launderingPolicy, approved by Assicurazioni Generali on 6 July2012 and then adopted by the other Group companiesworldwide. The guidelines in the document acknowledgethe recommendations of the Financial Action Task Forceand the provisions contained in Directive 2005/60/EC.The main objective is to highlight the conduct to be adoptedin order to prevent the use of financial transactions for thepurpose of money laundering - understood as the processby which proceeds from a criminal activity are disguisedto conceal their illicit origin - and financing of terrorism -which occurs when a person, by any means, directly orindirectly, provides or collects funds with the intention thatthey should be used or in the knowledge that they are tobe used, in full or in part, in order to carry out an offenceenvisaged by the legislation. The document also sets outthe responsibilities, duties and operating methods to beadhered to in risk management.The document governs related party transactions enteredinto, not only by Assicurazioni Generali, but by subsidiariestoo, with the objective of ensuring that said transactions arecarried out in observance of the principles of transparencyand substantive and procedural correctness.The Related Party Transaction Procedures areavailable on the websitewww.generali.com/GovernanceFurther details on the forms of corruption mentioned aboveare available in the section Corruption of this chapter.The Charter of Sustainability Commitments wasdrafted in the first few months of the year, a documentrequested by the Parent Company’s Top Management,which was approved by Assicurazioni Generali’s Board ofDirectors on 9 May 2013. It is an important document,which extends the approaches to managing objectivesrelating to significant aspects, adopted a few years agoin the environmental field, also to other relevant socialresponsibility issues. In fact, the Charter contains thestrategic objectives the Group intends to pursue as apriority and the social and environmental commitments tomeeting these objectives.The sustainability objectives and commitments includedin the Charter are not separate from the industrial ones,but instead supplement them, to help the Group reachthem by creating value for all stakeholders; therefore, firstof all, they are based on the contents of the new Codeof Conduct and the Business Plan of the Group. Theaforementioned strategic objectives and commitments willbe reviewed whenever deemed necessary, to ensure theyare always in line with social and environmental needs,the changes to Group activities and the expectations ofstakeholders.The document Sustainability Objectives and Commitmentsfor 2013-2015 constitutes an integral part of the Charter,which specifies the goals the Group undertakes to achieveover a three-year period. In particular, for each strategicobjective, medium- and short-term goals are identified inone or more macro areas (governance, clients, employees,contractual partners, community, environment and34 | Assicurazioni Generali - Sustainability Report 2012