Compliance: Code of Conduct

By adhering to the highest standards, we ensure behaviour across the Group that is compliant and demonstrates integrity.

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 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, policies, 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. The Code was overhauled in 2016 to include real-life examples and clearer guidance for day-to-day business situations. In 2018, updates were made to the Code including an update to reflect Swiss Re’s commitment to diversity and inclusion.

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.


Our 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

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

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”.

The Code is supported by our Global Policy on Financial Crime and our Global Standard on Anti-Bribery and Corruption, which emphasise 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 standard specify the correct procedures to be followed, including dealing with public officials and requesting approval in the gift and hospitality register.

Data protection

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

Our Data Protection Compliance Framework, with a global policy as well as local 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 by hosting events through the Swiss Re Institute that look at the future of regulations, new technologies, digitalisation, cross-border data processing, big data and innovation in life and health insurance. We offer additional information about our global data protection and privacy approach on our public website.

Money laundering

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

Our Anti-money Laundering Standard sets out in detail key requirements and guidance in relation to our anti-money laundering and counter terrorism financing efforts, including due diligence obligations concerning “know your counterparty”, counterparty and politically exposed persons (PEP) screening 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.


Swiss Re is strongly committed to maintaining a culture in which employees feel free to voice their concerns and report suspected misconduct. Accordingly, Swiss Re explicitly prohibits any retaliatory action be taken against employees who report suspicions of misconduct in good faith.

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 an external, independently operated whistleblowing hotline, which can be used anonymously (where legally permitted). Our whistleblowing hotline is also available to externals via our public website. The hotline includes translation services into numerous languages and is available globally.

All investigations of alleged Code violations involving either an employee or external contractor are handled by the Investigation Coordination Process (ICP). ICP, managed by the Compliance function, serves as a central coordinating unit across all Swiss Re offices globally and ensures that all investigations are handled in a consistent and fair manner. If, following an investigation, the allegations are substantiated, ICP will issue recommendations regarding any appropriate disciplinary or nondisciplinary actions that should be taken and oversees the actions to ensure fairness and consistency across the Group.

Misconduct cases are systemically presented and discussed with executive management, as well as with legal entity boards as part of the reports to board audit committees. In 2018, ICP cases reflected the following indicators:

  • The predominant channels for reporting ICP cases were through internal reporting directly to the Compliance department, line managers and members of the Human Resources team that were referred to ICP;
  • The large majority of ICP cases were related to theft of company property and misappropriation of assets through fraudulent acts;
  • In total, 65% of investigated cases of alleged misconduct were confirmed with respect to one or more of the allegations in question;
  • Disciplinary actions from substantiated investigations have been taken in 60% of the cases. The relatively low percentage of such actions should not be considered on a de-facto basis as an indication of weakness in culture. It is important to note that each investigation is fact- and circumstance-specific. There are certain criteria where disciplinary actions are generally delivered, eg where existing employees are found to have engaged in intentional misconduct. However, situations involving unintentional breaches will be considered substantiated, but may not result in disciplinary action.


All new permanent and temporary employees joining Swiss Re must undergo mandatory eLearning training on the Code, focusing on ethical behaviour in accordance with the principles of the Code and its relationship to Swiss Re’s values. Completion of the training is tracked and instances of non-completion are escalated until resolution.

All permanent and temporary employees also complete a periodic Code of Conduct Acknowledgement.

We deliver global eLearnings to remind and increase understanding of our key compliance risks and policy requirements. Last year, global eLearnings were delivered on Data Protection and International Trade Controls and Economic Sanctions. We also conducted global eLearnings for all our employees on the following compliance risks over the period from 2015 to 2018:

  • Anti-bribery and corruption
  • Anti-money laundering and terrorist financing
  • Conflicts of interest
  • Data protection
  • Fraud

In addition, local compliance officers regularly provide needs-based training on compliance risks tailored to their respective locations and/or areas of business.

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

In 2017, we enhanced the mandatory training escalation process for all Compliance Group-wide eLearnings to enable timely completion of assignments. Employees not complying with their mandatory eLearning assignments on time without valid reasons are subject to potential disciplinary action. For 2018 we achieved over 99% completion of all mandatory eLearning assignments including new hire and refresher training.

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. Eight Global Policies contain more detailed principles all employees have to be aware of, supporting the principles set out in the Code. Where necessary, underlying Global Standards are in place to provide additional detail on the specific requirements.


Code of Conduct

Code of Conduct Cover (photo)