Anti Financial Crime and Anti Bribery & Corruption

Assicurazioni Generali ("AG"), all its branches and majority-owned subsidiaries (“Generali Group”) are firmly committed participating in the efforts to combat bribery and corruption, money laundering, the financing and/or funding of terrorism activities, including the proliferation of weapons of mass destruction, and to ensure the respect of international sanctions requirements as set by UN, EU, US and any other relevant local authorities (not in violation of, or conflict with, applicable EU legislations). The overall mission of our Group is to conduct business in a sustainable and ethical manner. Our position is clearly stated in the Group Code of Conduct, in the Risk Appetite Framework Group Policy and in the AFC Group Policies and Guidelines which are applicable to the whole Group.

The various forms of financial crimes the Group is committed to combating are set out below.

We are committed to the highest standards of Anti-Money Laundering (“AML”) and Counter Terrorism Financing (“CTF”), including the prevention, suppression, and disruption of proliferation of weapons of mass destruction and its financing.

Our approach

Our group-wide standards and guidelines have the mission to identify and adopt all necessary measures to prevent the use of our financial services to launder money and finance terrorism, such as customer due diligence, continuous monitoring of clients and transactions, keeping a register of these checks, identifying suspicious transactions based on defined risk indicators and reporting them to the local Authority.
Our Group wide standards are based on the regulatory requirements on money laundering and terrorism financing, which are continuously monitored to ensure that we’re acting in compliance with the external laws.
We ask to all employees and third parties (i.e., agents, brokers, consultants) acting on behalf of the Group to comply with all our Group-wide standards and to effectively adopt all the actions aimed at preventing the laundering of money and the financing of terrorist activities.  

Training

We devote utmost importance to the trainings to our Group personnel as a way to further raise awareness on the risk of money laundering and terrorism financing and to protect our Group from those crimes.
A training program is established to provide adequate and periodic trainings to all employees, including dedicated training initiatives for the personnel exposed to higher risk of money laundering and terrorism financing (e.g., front line staff).
Our trainings include the key pillars related to the legal framework which applies to the Group, the internal policies and procedures, the duties, and responsibilities of each employee or third party and the potential scenarios by which the Group may be misused for money laundering and terrorist finance purposes and on the process to be followed to report any anomalous activity.

Reporting

The main purpose of our Anti-Financial Crime Program is to ensure the active collaboration with public Authorities through the detection and submission of any potential anomalous and suspicious activity.
The employees who know, suspect, or have reasonable grounds to suspect that money laundering or terrorist financing offence is being or has been committed or attempted must immediately report the suspicious activity following the internal processes.
In this respect, the Group ensures, through the adoption of appropriate measures, to protect the persons who report any suspicious activity. 

In line with the Group Risk Appetite Framework, Generali is committed to ensure the respect of applicable international sanctions requirements.

In this context the Group International Sanctions Policy establishes the International Sanctions group-wide minimum standards applicable to the relevant Group Legal Entities (GLEs), with the aim to support compliance with relevant legal and regulatory requirements, protect the Group’s reputation, and define principles and rules to ensure International Sanctions compliance across the Group. The document sets out roles and responsibilities, requires the correct allocation of risk’s ownership following the segregation of duties principle, and introduces risk mitigation measures such as due diligence, screening, contractual clauses, internal reporting, and training.

We condemn and combat all forms of bribery, corruption and related financial crimes.
We make our position clear in the Code of Conduct.
As a participant of the Italian network of UN Global Compact and that of Transparency International, we undertake to share, support and apply the principle of fighting against corruption in our spheres of influence.

Our approach

We strive to act responsibly, not limiting ourselves to simply respecting all national and international laws but promoting ethical and transparent conduct to strengthen our reputation among our stakeholders and increase their trust.
We ask all our stakeholders to engage in conduct to counter corruption and we also adopt measures to prevent conduct that is not in line with the principles of fairness, legality, and transparency.
We regularly monitor our exposure to all compliance risks to minimize potential damage to our reputation and economic losses deriving from the violation of laws in force, including those designed to prevent corruption. The Group policies have defined standards of conduct valid all over the world with the introduction of compliance programs that include actions to monitor the biggest risks.

Our employees and third parties who operate on behalf of the Group (agents, suppliers, consultants, etc.) must not offer or accept gifts or entertainment from public officials or business partners (or their relatives or business partners) that could be even only perceived as a bribe. The obligation to abstain from this conduct applies without exception in the case of unlawful payments such as bribes, payoffs or facilitating payments, which aim to speed up or facilitate the execution of routine operations. Gifts, entertainment or other benefits may only be offered or received provided they are of negligible value, are suited to the circumstances, are work-related, are permitted by local law and conform to the local commercial practice in use.

In addition, we do not endorse any event or initiative that is essentially or exclusively of a political nature, we refrain from exercising direct or indirect pressure on political representatives and we do not make any contributions to trade union associations.
Any charitable donations and sponsorships to the direct or indirect benefit of political parties or political exposed persons are clearly prohibited by our Code of Conduct.

Training

We believe that training is an important element of managing the risk associated with the different kinds of corruption, as it builds the necessary awareness and skills needed to stop them from happening. 
We provide adequate and continuous training for employees who are more likely to encounter corrupt practices and phenomena. The aim is to equip them with the skills needed to identify and manage activities potentially associated with the various forms of corrupt practices.
A training program is established and provided through dedicated meetings and courses delivered primarily via e-learning platforms and trough specific training activities are addressed to the Employees working in high-risk businesses. In particular, the training outlines laws and regulations, internal regulations and procedures, and case studies and practical examples, including potential scenarios that Employees may face.
The training raises awareness also on the available channels to seek advice, and on how to report any concerns or suspicions of bribery and corruption.

Reporting

Employees who become aware or have any concern of any violation of ABC standards must immediately report it through the whistleblowing system, as required by our internal rules related to the whistleblowing.