Annual Report 2022
Integrity and ethical conduct

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.

Code of conduct

a.s.r.'s code of conduct forms a guideline for its actions and decisions, and helps to perform its duties properly, with due care and integrity. It also forms a clear guideline for how employees interact with each other, how a.s.r. serves its customers and how a.s.r. takes its responsibility for the environment in which we work and live. The a.s.r. code of conduct applies to anyone who performs work for a.s.r., whether or not on a regular basis. a.s.r. expects everyone to observe the code of conduct and to call each other to account for compliance with it. The a.s.r. code of conduct is available on the website of a.s.r.

Every employee must take an oath or make a solemn affirmation. This demonstrates that the employee accepts and complies with the rules of conduct, and observe ethics in their actions.

Unethical behaviour

In order to guarantee sound and controlled business operations, a.s.r. has taken a number of control measures to prevent, identify and contest 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 also applies to contracting parties. 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. Moreover, in order to guarantee sound and controlled business operations, a.s.r. has taken measures such as monitoring and creation of awareness throughout the business with respect to insiders, incentives and outside business activities.

a.s.r. believes it is important that incidents are reported and that this can be done safely and with due care. a.s.r. has an internal reporting point for integrity incidents and a whistleblower scheme. Identifying and reporting incidents helps to detect irregularities and errors. This enables a.s.r. to learn from incidents and prevent them in the future.

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

a.s.r. has a policy on controlling unethical behaviour at the group and business levels. a.s.r. investigates signals of unethical behaviour, including corruption and fraud, from employees, intermediaries, 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 addressed in various policies, such as a.s.r.’s incentive policy and its anti-corruption policy. The latter also prohibits political contributions and charitable donations that act as a means of bribery and corruption 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 (SIRAs), 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 recognition and prevention of a.s.r. involvement in violations of laws and regulations or other socially undesirable acts. The fraud and corruption risks are part of the SIRA.

In 2022, 68 cases of alleged lack of integrity (2021: 108) were investigated by the investigations department. 23 disciplinary measures (2021: 55) were taken in cases of proven lack of integrity in the conduct of an employee, intermediary, or supplier. With respect to employee conduct, 6 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 addressing 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 NFRC, the a.s.r. Risk Committee and the A&RC of the SB. Where necessary, additional action is taken.