Sustainability Report 2012 - Generali Versicherung AG

The Generali Group is committed to fighting corruptionthrough a series of actions.Companies are obliged to adopt and periodically reviewthe appropriate internal means of control, complianceprogrammes and measures aimed at preventing andidentifying corruption, developed in accordance with arisk-based approach. Hence, for this reason, companiesare required to put in place procedures for the evaluationof risks that are consistent with not only their size andstructure, but their nature, scope and place of business.Companies must adopt financial and accountingprocedures that ensure than books, records and accountsare kept in the correct manner and are not used to engagein corruption or conceal acts of corruption.Lastly, raising awareness and training is no less important,which is described later in the section.The Code of Conduct and its Group Rules also provideadditional indications on how healthy relations must bemaintained with business partners. In particular, employeesare required to ensure that relations are documented bywritten agreements which make reference to the Group’santi-corruption policy. Payments made to businesspartners must comply with market conditions and mustnot be made to ciphered or numbered accounts.Assicurazioni Generali headquarter, piazza Duca degli Abruzzi 2, Trieste, ItalyAny exception must be authorised on a case-by-casebasis by the local compliance officer.Anyone that gains knowledge of gifts, invitations or otherbenefits that are suspected of wrongfully influencingcompany decisions is required to inform their manager orthe compliance department.The Group does not endorse any event or initiativeessentially or exclusively of a political nature, refrainsfrom exercising direct or indirect pressure on politicalrepresentatives and does not make any contributions totrade union associations in order to apply political pressure.Aware of the fact that charity and sponsorship contributionsmay be used for corrupt purposes, the Group requiresspecific preventive checks to be conducted on thebeneficiaries and provides instructions on how to makepayments.Acquisitions and mergers may also run the risk ofcorruption. Therefore, the Group requires due diligenceto be performed in advance, to identify any instances ofcorruption, considering a reasonable period of time priorto the date the corrupt act was carried out.The Code of Conduct and its Group Rules also deal withconflicts of interests, a situation which is generally avoidedand, where this is not possible, is managed in such a way asto avoid prejudice to the Group, and refer to the Related PartyTransaction Procedures in cases where the counterparty in atransaction is a related party of the Parent Company.Details on this document are available in the sectionPolicies and management tools of this chapter.Fraud, money laundering and terrorism financing aretypical examples of corruption that may occur in theinsurance and financial industry and which might damageorganisations’ reputation.Hence, the Group companies have adopted specificpolicies, detailed in the section Policies and managementtools in this chapter, and put in place an effective systemfor counteracting the aforementioned practices.It should be noted that, in Italy, in 2012, a project waslaunched with the objective of becoming an organisationthat permits a proactive approach to fighting fraud, basedon more integrated and quicker communication betweenthe various companies involved, an improvement in theculture of combating fraud, through information/trainingexercises for all employees, and a dedicated website.A new anti-fraud IT system is at the implementation phase,a deterministic and predictive analysis tool for identifyinganomalous and potentially fraudulent positions, to supportthe process of counteracting and preventing fraud. Inparticular, the use of predictive models makes it possibleto identify examples of fraud, generated by synthesising thetypical traits of similar instances of fraud. This new type of38 | Assicurazioni Generali - Sustainability Report 2012