Compliance: Code of Conduct

Our Code of Conduct (the “Code”) is one in a series of documents governing the organisation and management of our company. It sets the framework and defines the basic legal and ethical compliance principles 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: client centricity, agility, team spirit, passion to perform and integrity.

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 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. A comprehensively overhauled version will be published in the second half of 2016.

Key topics and policies

Our current version of the Code (valid as of 31 December 2015) addresses the following key compliance topics, amongst others:

• Antitrust (compliance with competition laws)
• Bribery and corruption
• Data protection and privacy
• Fraud (including tax avoidance)
• Inside information and insider trading
• International trade controls and economic sanctions
• Licensing and permanent establishment (including tax compliance)
• Money laundering
• Whistleblowing

The Code is supported by detailed policies and guidelines that document Swiss Re’s requirements in line with applicable laws and regulations.

The current Code is available to our employees in six languages: English, German, French, Italian, Spanish and Portuguese. The revised version will be published in two additional languages, bringing the total to eight.

Bribery and corruption

The Code addresses our position on bribery and corruption. This clearly states that “Swiss Re pursues a ‘zero tolerance’ policy with respect to bribery and corruption” and that “bribing governmental agents, regulators or other officials is a crime”.

In support, we implemented our Group Anti-Bribery and Corruption Policy in 2012. This clearly states that bribery, facilitation payments and hospitality where the giver is not present are always prohibited. For gifts, hospitality, sponsorships and charitable contributions, the policy and guidelines specify the correct procedures to be followed.

Money laundering

The Code draws attention to the risk of becoming unintentionally involved in money laundering and emphasises the importance of due diligence.

Our Anti-money Laundering Guidelines set out in detail key principles and guidance in relation to our anti-money laundering and counter terrorism financing efforts, including obligations concerning “know your counterparty” and the reporting of any suspicious activities.

Swiss Re’s commitment to sustainability

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

Whistleblowing

There are several ways in which alleged violations of the Code can be reported, both by internal and external sources. For our employees, these include a whistleblowing hotline, which they can use anonymously or with identification. The hotline is operated independently by an external vendor and includes translation services into numerous languages. The specific policies regarding whistleblowing differ between our offices, based on the applicable national laws of the respective country.

Training

All new permanent and temporary employees joining Swiss Re must undergo mandatory eLearning training on the Code. Completion of the training is tracked and instances of non-completion are escalated until resolution. The Code eLearning course was updated in 2015, putting the focus on ethical behaviour in accordance with the principles of the Code and its relationship to Swiss Re’s values. It has an interactive character and requires employees to assess behaviour and actions in various scenarios.

All permanent and temporary employees need to complete a Code of Conduct Acknowledgement every two years. The latest acknowledgement round was completed in 2015; it used a similar approach to the eLearning module, putting the focus on ethical behaviour and requiring our employees to apply the Code to a specific scenario.

In addition, we conducted trainings for all our employees on the following topics between 2013 and 2015:

• Anti-money laundering and terrorist financing
• Fraud
• Inside information and insider training
• Data protection
• Information security

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.