Compliance: Code of Conduct

By adhering to the highest compliance standards, we ensure legal and ethical behaviour across the Group.

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: 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 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 was published in the second half of 2016. While the requirements set out in the Code generally remain the same, many changes were made to make it a more user-friendly document. The language used in the new Code is easy to understand and concise. The new layout and real-life examples give us clearer guidance in our day-to-day business.

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

The new Code is available to our employees in eight languages: English, French, German, Italian, Japanese, Portuguese, Slovak and Spanish.

Our updated Code of Conduct

Code of Conduct

Updated Code of Conduct (cover)

Topics and policies

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

Our responsibility towards one another and Swiss Re

  • Business information and information technology
  • Communication
  • Conflicts of interest
  • Diversity & inclusion and fair and equal treatment
  • Fraud
  • Health, safety and security
  • Intellectual property

Our responsibility towards our business partners and society

  • Bribery and corruption
  • Data protection
  • Inside information
  • Fair competition
  • International trade controls and economic sanctions
  • Licensing and permanent establishment
  • Money laundering
  • Sustainability and human rights

Bribery and corruption

The Code addresses our position on bribery and corruption. It clearly states that “we conduct business fairly without accepting or offering benefits intended to improperly influence decision-making”.

In support, we implemented our Group Anti-Bribery and Corruption (ABC) Policy in 2012. This emphasises 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 standards specify the correct procedures to be followed.

In 2016, we integrated our ABC Policy in our Sensitive Business Risks assessment tool, which our underwriters use to screen transactions for potential negative impacts on the environment and human rights (see The Sensitive Business Risk process). This helps us to mitigate our exposure to bribery and corruption risks through appropriate due diligence on our counterparties.

Data protection

We could not work successfully with our business partners, clients and individual consumers around the world without maintaining their trust for the data they provide to us. The Code highlights that we need to handle personal data with greatest care and use it only for legitimate business purposes.

Our Data Protection Compliance Framework, with global as well as local policies and standards, addresses our commitment to protecting personal data and respecting privacy rights across our operations. We use internationally recognised data protection and privacy principles that ensure compliance with a complex and constantly changing set of laws and regulations, and we provide proper training and awareness sessions to our employees. Procedures for reporting security incidents and notifying on data breaches are established.

We also contribute thought leadership on data protection by conducting expert sessions during insurance industry events and hosting symposium events at our Centre for Global Dialogue to look at the future of regulations, cross-border data processing, big data, ethics and e-health in insurance (see Our Centre for Global Dialogue).

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 Standards 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.

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.


There are several ways in which alleged violations of the Code can be reported, both by internal and external sources. For our employees, the options are described in the Code and 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.


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 in the three years between 2014 and 2016:

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

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.