The a.s.r. code of conduct states that a.s.r. respects and endorses fundamental human rights, as recorded in the Universal Declaration of Human Rights, and that a.s.r. expects the same of its employees, customers and business relations. a.s.r. also endorses and respects the UNGPs and other standards, such as the OECD Guidelines for Multinational Enterprises, which prescribe human rights due diligence. a.s.r. runs the biggest risk of a negative impact on human rights with its investments. For that reason, human rights form the part of the core of its policy in the field of responsible investment. Other negative impacts may arise with commercial customers, via products and services, via procurement and in respect of a.s.r.’s own employees.

Investments

All a.s.r. investments are monitored for compliance with the ESG criteria based on a.s.r.’s Socially Responsible Investment (SRI) policy, which includes criteria for human rights and labour rights. Countries and companies that do not comply with these are excluded. Companies that commit systematic and / or serious violations of human rights (as recorded in the International Bill of Human Rights), or companies that do not respect the fundamental ILO conventions, will be excluded or will be given an opportunity to improve in a dialogue. In 2021, engagement took place in relation to the subjects of forced labour, modern slavery, the human rights situation in Myanmar and living wages, including with JA Solar and Total. More information on this can be found chapter 3.2.1.

Business customers

Since the Sustainable Insurance Policy was approved in 2021, a.s.r. also tests business customers in terms of the ESG criteria on the basis of the SRI policy. Serious or repeated violations of the principles of the UNGC (on matters including human rights and labour rights) are assessed. In 2021, no customers were rejected on the basis of human rights or labour rights violations. More information on this policy is presented in chapter 3.1.1.

Impact via products and services

At the end of 2021 and during the first months of 2022, a.s.r. determined the extent to which its products and services have a potential negative impact on the human rights of its customers through a human rights risk analysis. This showed that a.s.r.’s products and services generally have little negative impact. This provided valuable insights in specific risks and also provided a.s.r. with opportunities for improvement through adjustments of processes and policies. One risk that was identified regards customers in a debt situation that are unable to pay their insurance premiums and as such cannot exercise their right to social security and do not have an adequate standard of living. In order to mitigate this risk, a.s.r. has amongst others signed the Ethical Manifesto. Another risk that was identified is linked to the inaccessibility of information for (functionally) illiterate costumers. a.s.r. is addressing this risk via a variety of initiatives, such as a cooperation with Stichting Lezen & Schrijven.

Impact via procurement

In 2021, a.s.r. tightened its procurement process, including in the field of human rights, and on the basis of (international) guidelines and standards in the fields of social responsibility, such as the OECD guidelines for Multinational Businesses, the UNGC initiative and the UNGPs. On the basis of the procurement process and the Customer Due Diligence (CDD) policy, a.s.r. checks suppliers for human rights and labour rights, and for environmental and business ethics-related risks and impact. This information is used to avoid or reduce negative impacts. With these checks, a.s.r. ensures that due diligence is observed in procurement procedures. a.s.r. also requires suppliers to exercise due diligence in their own business activities and in their supply chains. a.s.r. intends to develop a Supplier Code of Conduct no later than in the first half of 2022, with more specific expectations for compliance with the human rights standards.

Impact as employer

a.s.r. also respects the right to equal treatment and non-discrimination as an employer. Everyone is welcome at a.s.r. and everyone receives equal treatment, precisely through organisation-wide awareness of diversity in gender, age, religious conviction, physical and mental abilities, background and orientation. Via the Diversity, equality and inclusion policy, a.s.r. aims for a balanced composition of the workforce on the basis of age, gender, cultural or social origins, competences, views and working styles. The code of conduct explicitly devotes attention to a safe and comfortable working environment versus discrimination and exclusion. With the Denison scan, the extent to which a.s.r. employees regard the company as an inclusive employer is surveyed every year. In the event of experiences with undesirable conduct such as bullying or discrimination, employees can contact an external confidential counsellor. This occurred 14 times in 2021 (2020: 16 times). Employees can also contact officers within the organisation with questions or dilemmas. The complaints committee for inappropriate behaviour handles complaints in confidence and can give the complainant advice. Just like in 2020, in 2021, the committee was not consulted.