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 and the oath or solemn affirmation
a.s.r.'s code of conduct constitutes a guideline for actions and decisions, and helps the company to fulfil its duties properly, with 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 it operates. The a.s.r. code of conduct applies to anyone who works for a.s.r., whether on a regular basis or not. a.s.r. expects everyone to observe the code of conduct and to hold each other to account for compliance with its stipulations. The a.s.r. code of conduct can be found on www.asrnl.com.
When starting employment at a.s.r., every employee, including temporary- and external employees, must take an oath or make a solemn affirmation. This demonstrates that they accept and comply with the rules of conduct, and observes ethical principles 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 combat 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 extends to contracting parties. With these measures, a.s.r. seeks to prevent the risk of physical, financial or reputational damage to the company, its customers and/or other stakeholders and business relations. Complementary, a.s.r. has taken measures such as monitoring and the stimulation of awareness throughout the business with respect to conflicts of interest.
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 route for integrity incidents (included in the Code of Conduct) and a whistleblower scheme. Identifying and reporting incidents helps to mitigate 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 threat. The whistleblower policy revised in 2024 provides for the reporting of alleged malpractice and irregularities’.
a.s.r. has a policy on controlling unethical behaviour at group and business levels. a.s.r. investigates signs of unethical behaviour, including corruption and fraud, among employees, intermediaries, mandated brokers and suppliers. a.s.r. has a zero tolerance policy. Should integrity be compromised, for example through corruption and/or fraud, a.s.r. will take appropriate measures, with due regard for the applicable legislation and 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 may serve as means of bribery and corruption. 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’. By performing systematic integrity risk analyses (SIRAs), a.s.r. maps integrity risks and determines which additional control measures must be taken if any risks fall outside the risk appetite. The SIRA contributes to the detection and prevention of involvement with violations of legislation and regulations or other socially or ethically undesirable acts. The fraud and corruption risks are part of the SIRA.
In 2023, 86 cases of alleged lack of integrity (2022: 68) were investigated by the investigations department. 23 disciplinary measures (2022: 23) were taken in cases of proven lack of integrity in the conduct of an employee, intermediary, or supplier. With respect to employee conduct, 10 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. Where necessary, additional action is taken.