Sustainability Report 2012 - Generali Versicherung AG

analysis will supplement the current deterministic methodalready available in claims, car and accident systems,extending the anti-fraud analysis to the life segment, tothe non-life lines of business still not covered and to theproduction networks, according to a single paradigm.The measures which must be adopted by Generali Groupcompanies to prevent instances of money laundering andterrorism financing include: performance of customer duediligence according to a precise framework, the obligationto keep a log of the data obtained from the aforementioneddue diligence, identification of suspicious customers and/or transactions on the basis of risk indicators defined andreporting of these to the local Financial Information Unit.Companies are also obliged to have the necessarycontrols and tools in place for effective and efficient riskmanagement.These must be consistent with their characteristics, size,organisational structure, subject responsibility, productsand market conditions.Finally, companies are requested to send a detailed reporton money laundering and terrorism financing to the HeadOffice department responsible at least once per year, and topromptly notify said department if any events should occurthat could expose the Group to high reputational risk.In the second half of 2012, a questionnaire was circulated,prepared on the basis of specific matters (governance,customer due diligence, conservation and archiving ofdata, fight against international terrorism and training),with the objective of monitoring all Group companies interms of anti-money laundering aspects.With a view to constant improvement, the Generali Groupintends to develop its policies further, by issuing a globalembargo management policy, technical instructions onboth the periodic control of information relating to customerdue diligence, and on politically exposed persons, aswell as operating guidelines for the management ofpotentially suspicious transactions that may indicatemoney laundering and on procedures of onboarding ofgiven categories of customers. Other objectives concernthe preparation of a rigorous system for the monitoringof methods of domestic payments and the adoption ofa standard Group tool for the management of prejudicialinformation concerning actual or potential customers.Training is an important component of risk management,as it creates internal awareness and the skills needed toprevent cases of corruption.Therefore, the Generali Group offers adequate andcontinuous training to its employees who might morereadily come into contact with the most significantexamples of corruption for the sector, such as fraud,money laundering and terrorism financing, and, if deemednecessary, its agents and their collaborators. The goalis to provide them with the necessary tools to identifyRadici del presente Museum, Rome, Italyand manage activities potentially connected with theaforementioned forms of corruption.Training is carried out through specific meetingsand courses given, predominantly via the e-learningmethod. E-learning is the chosen method, for example,for disseminating the contents and principles of theOrganisation and Management Model to all employeesand agents of Italian Group companies, and for providingtraining on money laundering and terrorism financing to theemployees of Italian Group companies that are obliged tocomply with the legislation, agents and their collaborators.Awareness of corruption is created through the explanatorynotes and concrete suggestions in the new Code ofConduct and in its Group Rules. Training programmeswill be provided to all employees in the near future onthe Code of Conduct and the Group Rules, and ad hoctraining initiatives, focused on compliance programmesfor the prevention and identification of instances ofcorruption, will be provided to employees considered atrisk of encountering corruption.Various Generali Group companies participate in activitieson the subject of corruption proposed by local insuranceand banking associations.The above actions make it possible to mitigate the risk ofcorruption and reduce the number of instances of corruption.In this regard, in 2012, no reports of unethical conductwere received through the appropriate communicationchannels established. However, a limited number ofinstances of fraud committed by employees or businesspartners of Group companies were otherwise detectedand managed. The actions taken in response were mainlydismissal, the adoption of disciplinary measures and thetermination of contracts, depending on the interestedparty (employee/business partner) and the gravity of theoffence.the group | 39