Compliance

Our Code of Conduct (“Code”) is one of the key documents governing the management of risks and driving the culture within our company. It sets the framework and defines the basic compliance and integrity principles that we adhere to globally. The Code is built on the five Swiss Re values, which guide us in making responsible decisions and achieving results using the highest ethical standards: integrity, team spirit, passion to perform, agility and client centricity.

The Code also offers practical guidance and examples for deciding the appropriate course of action and solving ethical dilemmas. It further sets out how all employees should react when they observe a possible breach of the principles in the Code. All employees are obligated to uphold both the letter and spirit of the Code, its policies and standards, and the Group’s corporate governance principles in their daily business activities, and to respect and obey applicable laws and regulations in all jurisdictions where we do business.

We regularly review and update the Code to reflect changes in regulations and principles. In 2021, updates were made to clarify how employees are expected to act as “One Swiss Re” and to set out the Group’s commitment to take ethical responsibilities (including digital and data ethics) into account when making decisions. The Code is supported by detailed policies and standards that document Swiss Re’s requirements in line with applicable laws and regulations. It is available to our employees in eight languages: English, French, German, Italian, Japanese, Portuguese, Slovak and Spanish.

Assurance

Assurance activities to monitor adherence to the Code are a core part of our Compliance Programme. Compliance performs independent risk-based monitoring to ensure adherence to, and the efficiency of, processes and controls mitigating our key compliance risks across Swiss Re. In 2021, we continued our efforts to drive our digitalised, data-driven strategy to better tailor assurance activities in identifying and generating deeper insights.

Policies

Our Code addresses the following key compliance topics under the two headings “Our responsibility towards one another and Swiss Re” and “Our responsibility towards our business partners and society”:

Below we present additional information on some key topics in the Code:

Bribery and corruption

The Code addresses our position on bribery and corruption. Operationally, we have a Global Framework for Anti-Bribery and Corruption (“ABC Framework”), including policies, standards, training, assurance activities, enabling advice and tools to help manage these risks. In 2021, we reduced our Gift & Hospitality Register threshold requirements for public officials, based on a global review of regulatory requirements, risk exposure and industry benchmarking. Additional information on the ABC Framework can be found on the Preventing Financial Crime and Sanctions Violations page at swissre.com (see below).

Data protection

The Code highlights that we need to handle personal data with the greatest care and use it only for legitimate business purposes. Operationally, we have a Global Framework on Data Protection (“DP Framework”), including policies, standards, processes (eg reporting security incidents, notifying of data breaches), training, assurance activities, enabling advice and tools to help manage this risk. This DP Framework and the Digital Governance Framework (see Digital responsibility) together address our commitment to protecting personal data and respecting privacy rights across our operations, including all digital projects. Within the DP Framework, we apply internationally recognised data protection and privacy principles that ensure compliance with a complex and constantly changing set of laws and regulations.

Money laundering, international trade controls and economic sanctions

The Code draws attention to the risk of becoming involved in money laundering and emphasises the importance of due diligence. Additionally, it commits us to adhere to all applicable international trade controls and economic sanctions as well as internal requirements (that may be stricter) to protect us against entering into prohibited business arrangements. Our Global and Local Frameworks on Anti-money Laundering and International Trade Controls and Economic Sanctions are supported by a Global Policy on Financial Crime and Sanctions and set out in detail key requirements and guidance for complying with applicable laws and regulations. Additional information can be found on the Preventing Financial Crime and Sanctions Violations page at swissre.com (see below).

Sustainability and human rights

The Code includes our formal commitment to sustainability and human rights, providing a guiding principle for our efforts to act as a responsible company.

Reporting misconduct, whistleblowing and investigations

Continuing from 2020, the #SpeakUp campaign, an internal awareness initiative to help nurture a “speak up” culture, published four articles on our enterprise portal during 2021. Each article featured a real Swiss Re misconduct case that had been reported and investigated through the internal investigation coordination process, with the aim of encouraging employees to speak up if they suspect misconduct has occurred and remind them of all available reporting channels. Compared to 138 page views in 2020, #SpeakUp’s published materials surpassed 4 800 views in 2021. New in 2021, a related initiative entitled “High Performance with High Integrity dialogues” was launched to all Swiss Re employees. The initiative provided all line managers with real Swiss Re case materials to facilitate a dialogue within their teams and discuss Swiss Re’s desired behaviours, reporting channels and investigation process. As a result, we believe this allows our employees to better understand how they should act and what they can expect when faced with a suspected misconduct situation.

Misconduct cases are systemically presented and discussed with the Group Executive Committee, the Group Board of Directors, the Group Audit Committee as well as with legal entity boards as part of reports. In 2021, ICP cases reflected the following indicators:

• 67 cases were investigated by ICP in 2021 and 59 were closed.
• Of the 59 cases closed in 2021, 69% were substantiated and 31% were not substantiated.
• The reporting intake methods for the ICP cases that were investigated in 2021 were: internal channels, including reporting directly to Compliance, via line managers and via Human Resources (69%); external sources (9%); the whistleblowing hotline (10%); and process detection (12%).
• The categories of ICP cases investigated in 2021 included: external fraud (36%); discrimination and harassment (including bullying) (27%); internal fraud (4%); insider trading (including accidental trading within a close period and misuse of confidential business information) (13%); and various other Code violations (17%), none of which individually exceeded 9%.
• Of the 67 cases that were investigated, 36% were due to the actions of external actors and 64% were due to the actions of internal personnel.
• Disciplinary actions, including termination, written warnings, verbal warnings and performance rating adjustments, were taken in 37% of substantiated cases. The relatively low percentage of such actions should not be taken as an indication of a weak Compliance culture. It is important to note that each investigation is fact- and circumstance-specific. There are certain circumstances where disciplinary actions are nearly always imposed, such as where active employees are found to have engaged in intentional misconduct. However, there are also circumstances where allegations are substantiated but may not lead to disciplinary action, such as cases involving unintentional breaches, cases where the perpetrator(s) cannot be identified, and cases involving external fraud. In cases involving unintentional conduct, in lieu of disciplinary action, non-disciplinary recommendations will be made, such as additional training activities or increased supervision.
• In each case, regardless of the outcome, ICP ensures that any lessons learned from the investigation are communicated within the Compliance function as well as to any relevant stakeholders. In addition, training and communications are updated, and controls and processes are adapted as necessary.

Training

All new permanent and temporary employees joining Swiss Re must undergo mandatory eLearning training called Compliance and our Culture, which focuses on the Code and additional ethical behaviour in accordance with Swiss Re’s values. It also includes individual modules on the following compliance topics:

• Anti-bribery and corruption
• Anti-money laundering and terrorist financing
• Conflicts of interest
• Data protection
• Fraud
• Insider trading
• International trade controls and economic sanctions

In addition, we deliver mandatory global eLearning sessions to employees to remind them as well as increase their understanding of our key compliance risks and policy requirements. Last year, global eLearning sessions were delivered on data protection, international trade controls and fraud. Over the period from 2018 to 2021, we also conducted global eLearning sessions on the following additional compliance risks:

• Anti-money laundering
• Bribery and corruption
• Insider trading

Local compliance officers regularly provide risk-based training on compliance risks that is tailored to their respective locations and/or areas of business. Tailored training on topics including conduct risk and investment compliance risks is provided in this way.

Training on Code of Conduct topics falling outside the Compliance mandate are managed similarly by the responsible functional areas.

We take timely completion of mandatory training seriously. Completion of training is tracked, and instances of non-completion are escalated until resolution. Employees not complying with their mandatory eLearning assignments on time without valid reasons are subject to potential disciplinary action. For 2021, we achieved 100% completion of all mandatory eLearning assignments, including new hire and refresher trainings.

Annual attestation process

In March 2021, the annual attestation process was launched for all permanent and temporary employees to acknowledge personal accountability for complying with specific requirements related to the Code and Global Compliance Policies and Standards. These include responsibility for personal conflict of interest and gift and hospitality register disclosures.

Validity for third parties

Third parties representing Swiss Re – such as consultants, intermediaries, distributors and independent contractors – should be carefully selected and need to comply with the Code and relevant policies. When we work with such third parties, we provide them with information about the relevant requirements and, in the event of any infringements, take appropriate action, up to and including terminating a contract.

Policy governance

A policy management tool serves as a central place for finding Swiss Re policies and standards. Supporting the principles set out in the Code, Swiss Re has eight global policies containing more detailed principles that all employees must adhere to. Where necessary, underlying global and targeted standards and processes are in place to provide additional details on the specific requirements.