Annual Report 2022

a.s.r. employees keep their knowledge up to date through yearly compliance trainings, 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. Topics that were brought to the attention in 2022 include outside business activities, incentives, privacy, Customer Due Diligence, information security, sustainability, social media code, inside information and diversity, equity and inclusion (DEI). In addition, all a.s.r. employees receive three mandatory questions every month on the a.s.r. code of conduct, information security and cybercrime.

In 2022, (mandatory) training courses were organized to increase awareness and knowledge of CDD-related legislation and regulations (including the Anti-Money Laundering and Anti-Terrorist Financing Act). In 2023, Compliance will continue its awareness programme on the a.s.r. code of conduct.

Ethical themes

Employees are encouraged to speak up regarding integrity issues and engage in dialogue with each other. a.s.r. facilitates open dialogue throughout the company on ethical dilemmas and challenges that arise during daily business by organizing ethics workshops and dilemma sessions. This stimulates and strengthens ethical awareness among employees. In 2022, four ethics sessions were organised to develop ethical awareness and encourage critical reflection and informed decision-making on the following topics:

  • Ethical data use;

  • Diversity equity and inclusion;

  • Sustainable business practice.

Ethical sessions organised

(in numbers)


Ethical sessions organised

(in numbers)


Ethical framework for data-driven applications and decision-making

In cooperation with the Dutch Association of Insurers (Verbond van Verzekeraars), a.s.r. has developed an ethical framework for data-driven applications and decision-making, as a form of binding self-regulation for the insurance sector. This framework helps the organisation implement an ethical data vision and invites critical reflection on issues such as discrimination and exclusion, accessibility of data applications, privacy, transparency and explicability.

Ethical data use requires customer trust, a self-aware vision regarding desirable contexts of data collection to generate useful insights, and the appropriate tailoring of these insights to product and service delivery to serve customer interests. In an increasingly data-driven world, critical reflection is needed to avoid risks of discrimination and exclusion, keep applications accessible for vulnerable groups and protect customers’ autonomy and self-determination, as well as their privacy, in all relevant processes.

By implementing the ethical framework for data applications in all layers of the organisation, all business units, departments, disciplines and employees involved in the data journey of customers throughout a.s.r. act in more ethically responsible ways, carefully considering important ethical themes and risks. In 2022, the following activities were organised to promote more awareness:

  • Awareness sessions were organised for different departments to promote familiarity with the framework, its background and intended application in practice;

  • Ethics sessions and workshops were organised to practice working with the ethical framework and help colleagues translate its elements to their daily practice;

  • A (e-learning) training programme was developed for managers, to promote awareness about the ethical framework at management level and activate business units to actively use the framework by implementing it in all relevant sub-departments and data processes that are involved in core customer processes (i.e. marketing, underwriting, pricing, claims, and fraud).

Diversity, equity and inclusion

A diverse, equal and inclusive working environment is essential for an organisation and its employees. Not only to make full use of people’s diverse qualities and perspectives for better decision-making, but also to better understand the diversity of customer needs, to inspire equal treatment of the interests of all internal and external stakeholders and promote a safe, pleasant and inclusive working atmosphere. The goal is to realise a working environment where mutual understanding, attention and empathy are central and everyone is given the space to be themselves and provide their input.

Dialogue sessions, panel discussions and other initiatives are organised on a regular basis to draw attention to these topics, allow colleagues to engage in dialogue with each other and explore how the organisation can further improve on these themes.

Sustainable business practice

a.s.r. wants to do business in an increasingly sustainable way. To properly weigh all interests involved requires ethical self-awareness and critical reflection. This leads to complex ethical considerations in daily practice, where the following questions need to be answered:

  • How to determine the moral weight of all the stakeholder interests involved?

  • Which moral duties and principles, ethical preconditions or frameworks help prevent risks, including risks in terms of (unintentional) discrimination and exclusion and possible human rights violations in value chains?

  • How does the organisation fulfil its moral responsibility to promote value chains with integrity, through constructive and effective cooperation between all stakeholders and parties involved?

To advise the organisation on these complex dilemmas, a Sustainability Committee was created, to discuss issues regarding sustainable business practice and provide tools and support for business units to make ethically self-aware choices that are in line with a.s.r.’s vision and strategy.

Ethics sessions 2022

In 2022, four ethics sessions were organised to develop ethical awareness and encourage critical reflection and informed decision-making.

Dilemma session rural real estate

Dilemmas were discussed in relation to lessees, tenants and to other initiatives being developed on land belonging to a.s.r. How do initiatives contribute to sustainability and sustainable impact? What frameworks and preconditions are there ethically to guide decision-making and acceptance criteria?

  • Participation: rural real estate with approximately 20 people;

  • Topics: sustainable land use, engagement with lessees/tenants, ethical acceptance criteria and critical reflection on social impact;

  • Results: critical ethical reflection on the above themes. In addition, an a.s.r. Sustainability Committee is being set up to provide central advice and support on sustainability dilemmas in all business units, as well as on dilemmas in underwriting criteria in a dynamic world with a complex field of stakeholders.

Data stewards Individual life and Pensions

Dilemmas around ethical data use took centre stage. Colleagues in their new role as data stewards practised using the ethical framework for data applications for their daily practice. How do you take ownership of (sensitive) customer data? In this, how do you work well with the departments and disciplines involved, all of which are part of the data puzzle?

  • Participation: data stewards of Individual ife and Pensions (twice, with approximately 10 people on each occasion);

  • Topics: ethical data use, the ethical framework for data applications and decision-making;

  • Results: critical reflection on taking ownership of sensitive customer data by putting the customer perspective and their data journey at the centre of collaboration with other colleagues within a.s.r. Awareness and practice with the ethical framework and its application to their daily practice.

Ethical data use in customer contact

Dilemmas about ethical customer contact based on data were discussed. Profiling using customer data can better predict customer preferences and needs. But which data types and contexts are justified in doing so? When and how do you act towards customers based on those profiles or insights? How do you optimally protect their privacy without losing sight of good service and targeted product offers in the customer's interest?

  • Participation: colleagues involved in customer contact (and customer contact strategy);

  • Topics: ethical data use, the ethical framework for data applications and decision-making, privacy versus customer-focused service;

  • Results: critical reflection on customer contact, service in the customer interest, critical reflection on customer profiles and data insights (what do they really say?).

Awareness session ethical framework with data scientists

Session aimed at promoting awareness of the ethical framework. Critical dialogue about the contexts in which customers are tracked on the basis of data, what insights this generates and how a.s.r. acts on this responsibly in the customer’s interest, without harming customers’ autonomy and privacy. Is it responsible to track customers online? For which products and services do you act more quickly towards customers on the basis of (moral) duty of care? How do you protect autonomy and privacy?

  • Participation: data scientists and marketers from (with approximately 20 people);

  • Topics: ethical data science, data collection, actions towards customers, customer autonomy and privacy in online environments;

  • Results: awareness of a.s.r.'s ethical data applications framework, its use for critical dialogue and reflection on dilemmas concerning data use.