Observance of applicable sanctions regulations plays a central role for us on account of our international orientation. We have enshrined compliance with relevant sanctions provisions in our Code of Conduct and Underwriting Guidelines. In addition, a Sanctions Screening Guideline is in place, stipulating when members of staff must perform sanctions screening with respect to the initiation of contracts and/or the payment of claims. A software-supported check continuously verifies whether the company's data inventories include the names of persons who are subject to sanctions and hence with whom no business may be transacted. Each working day staff in Group Legal check the Official Journal of the European Union for changes in sanctions law on the EU level and publicise relevant changes Group-wide without delay.

In the year under review a new, comprehensively revised Sanctions Guideline entered into effect. More than 500 employees in underwriting and technical accounting have been trained in the new check rules. For the first time, the guideline contains systematic rules governing not only the topic of financial sanctions – with the associated crosschecking of customer names against lists of persons subject to an assets freeze – but also the screening of goods and services.

The training given to new members of staff also includes a section on sanctions, with the result that all new employees receive basic instruction in sanctions law. New underwriters and claims managers receive additional training in the use of the screening software as well as in the scenarios in which a sanctions check must be made. Further training activities are offered as needed and on an individual basis for affected departments.