Integrity and ethical conduct are prerequisites for a.s.r.’s reputation as a trustworthy insurer. In addition to the use of clear frameworks, sound and controlled business operations are above all driven by sound, intrinsically embedded core values and ethical behaviour.

The a.s.r. code of conduct sets out the required attitude and behaviour of a.s.r.’s employees. The aim of the code is to protect a.s.r.’s reputation through the integrity and professional conduct of all its employees. For more information about the a.s.r. code of conduct, see www.asrnl.com.

a.s.r. continuously emphasises the importance of the a.s.r. code of conduct and its underlying policies and rules, and invests in awareness-raising. In 2021, it took various initiatives to further improve knowledge on integrity-­related subjects. a.s.r. employees keep their knowledge up to date through compliance training, presentations and dialogue, but also, for example, through (voluntary) gamification. By answering relevant questions each day, employees can refresh their knowledge of the code of conduct. Training of employees covers the main compliance-related topics, with a focus on the code of conduct, conflicts of interest (e.g. insider trading, outside business activities and incentives), CDD, privacy and cyber risk. In mid-2020, a.s.r. launched an awareness programme on avoiding conflicts of interest, this programme ran to mid-2021. In 2021 attention was focused on outside business activities. Compliance will continue to implement compliance awareness programmes in 2022 and 2023.

In order to guarantee sound and controlled business operations, a.s.r. has taken a number of control measures to prevent, recognise and defy unethical behaviour, including combating corruption. Examples of control measures include integrity screening carried out by the investigations department prior to hiring new employees as well as in-employment screening. This integrity screening applies to contracting parties as well. All employees have taken an oath or made a solemn affirmation promising to comply with legislation and regulations and codes of conduct and observe ethics in their actions. This also applies to everyone who regularly works for a.s.r. Anyone who carries out work at or for a.s.r. must take the professional oath or make a solemn affirmation within three months of taking up their duties. In this way, a.s.r. seeks to prevent the risk of physical, financial or reputational damage to the company, its customers and / or other business relations.

a.s.r. has a policy on controlling unethical behaviour at group and business level. a.s.r. investigates signals of unethical behaviour, including corruption and fraud, from employees, advisors and suppliers. Should integrity be compromised, including through corruption and / or fraud, a.s.r. will take appropriate measures, with due regard for the applicable laws, regulations and sector-based protocols. The risk of corruption is dealt with in various policies, e.g. a.s.r.’s incentive policy and its anti-corruption policy. In this policy is also included that political contributions and charitable donations that act as a means of bribery and corruption are not allowed by a.s.r. a.s.r. uses the definition formulated by the DNB: ‘The risk of corruption is the risk of financial companies in the Netherlands being involved in bribery and / or conflicts of interest which impair the integrity of, and trust in, that company or in the financial markets’. a.s.r. operates a policy of zero-tolerance. By performing systematic integrity risk analyses (SIRA), a.s.r. maps integrity risks and determines which additional control measures must be taken if the risk falls outside the risk appetite. The SIRA contributes to recognising and preventing that a.s.r. gets involved in violations of laws and regulations or other socially undesirable acts. The fraud and corruption risks are part of the SIRA.

Under the whistleblower scheme, employees and third parties, including former employees, clients and other contracting parties, can report alleged malpractice anonymously, freely and without feeling threatened.

The compliance department monitors sound and controlled business operations, including reputational risks. The framework for monitoring and reviewing is based on the rules, regulations and standards of a.s.r. itself, including the a.s.r. code of conduct. In 2021, the compliance department monitored compliance with e.g. the rules, regulations and policies on CDD, General Data Protection Regulation (GDPR), remuneration, product approval and review process, handling client requests, intra-group outsourcing, internal exchange of company sensitive and / or price sensitive information and the registration and reporting of data breaches and the quality of information provided to clients. The compliance department played an advisory role in a.s.r.’s CDD optimisation project.

In 2021, 108 cases of alleged lack of integrity (2020: 92) were investigated by the investigations department. 55 disciplinary measures (2020: 49) were taken in cases of proven lack of integrity in the conduct of an employee, advisor or supplier. With respect to employee conduct, five employees were found to have violated the a.s.r. code of conduct. Following investigation, a lack of integrity, e.g. fraud and inappropriate conduct or behaviour, was proven. These employees were disciplined for the infringement of the company’s principles. This resulted in the addressing of undesirable behaviour, a written warning or dismissal. The investigations department reports quarterly on the number of incidents and the measures taken. This report is discussed with the EB, the Non-Financial Risk Committee (NFRC), the a.s.r. Risk Committee and the A&RC of the SB. Where necessary, additional actions are taken.