a.s.r. employees increase their knowledge regarding compliance topics through yearly training courses, presentations, dialogue and through (voluntary) gamification. By answering pertinent questions daily, employees can refresh their knowledge of important topics within the code of conduct. Topics that were highlighted in 2023 include outside business activities, incentives, privacy, Customer Due Diligence, information security, sustainability and insider trading. In addition, all a.s.r. employees are regularly presented with three mandatory questions regarding the a.s.r. code of conduct, information security and cybercrime. A new tool was implemented for this purpose in the beginning of 2024.

For a select group of employees who perform CDD-related activities, a mandatory training programme and an education programme concerning CDD-related legislation and regulations (including the Anti-Money Laundering and Anti-Terrorist Financing Act) were rolled out in 2023.

Ethical themes

Employees are encouraged to speak up regarding integrity issues and to engage in dialogue with each other about daily dilemmas in the company. a.s.r. facilitates open dialogue throughout the company on ethical dilemmas and challenges that arise during daily business by organising ethics workshops and dilemma sessions, as well as by developing ethical guidance for specific topics and themes where relevant and desirable. This encourages and strengthens ethical awareness among employees. In 2023, 13 ethics sessions were organised to develop ethical awareness and encourage critical reflection and informed decision-making, mainly focusing on the following topics:

• Ethical data use;

• Diversion, equity and inclusion;

• Sustainable business practice;

• The integration of a.s.r. and Aegon NL.

Ethical data use

In cooperation with the Dutch Association of Insurers, 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 a.s.r. to 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 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.

In 2023, 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;

• An obligatory e-learning course for managers promotes awareness of the ethical framework at the management level and activates 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);

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

• Workshops were organised to structure the new Machine Learning Platform within a.s.r. Specific attention was given to the embedding of the ethical framework in the risk management processes surrounding the development of new artificial intelligence applications within a.s.r.

Diversity, equity and inclusion

Dialogue sessions, panel discussions and other initiatives are organised on a regular basis to draw attention to topics, related to diversity, equity and inclusion. Colleagues are encouraged to engage in dialogue with each other and explore how a.s.r. can further improve on these themes. Further information about diversity, equity and inclusion can be found in section 3.3.1.

Sustainable business practice

a.s.r. wants to do business in an increasingly sustainable way. Proper assessment of 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 the risk 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?

• How to promote consistency and integrity in a.s.r.’s different roles as a company with regard to the implementation of sustainable policies, to ensure that any discrepancies between business lines are critically reflected upon and morally justifiable?

The Sustainability Committee within a.s.r. advises the organisation on these complex dilemmas by discussing issues regarding sustainable business practice and providing tools and support for business units to make ethically self-aware choices that are in line with a.s.r.’s vision and strategy. In 2023 the Sustainability Committee made seven recommendations regarding sustainable business practices.

The integration of a.s.r. and Aegon NL

Conduct and culture is Compliance’s purview within the organisation. Through advice, monitoring and stimulation of awareness regarding risks in daily operations, Compliance hopes to foster an ethically aware culture, with integrity and appropriate conduct and risk awareness. Due to the integration of Aegon NL, the importance of a strong and coherent culture becomes even greater. A culture wherein colleagues collaborate well together to bring the best of both worlds (in terms of policies, guidelines, processes, and other aspects of daily practice) together and create a strong, ethically aware and risk aware company that serves its stakeholders and society in a sustainable way. To this end, Compliance will pay extra careful attention to the process of integration in all relevant business lines within a.s.r. the next couple of years. 

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