We consider an efficiently functioning compliance structure to be an essential tool for ensuring fulfilment of external rules as well as requirements imposed internally within the company. Our compliance structure was reviewed and adjusted most recently in 2015 against the backdrop of the compliance requirements associated with Solvency II.
The Chief Compliance Officer and the Compliance Department keep employees informed about changes in legislation, insofar as they affect their work. A worldwide network of compliance officers at the international locations reports to and supports the Chief Compliance Officer in his duties. This means that local compliance violations can also be reported directly outside the local hierarchy. The Chief Compliance Officer updates the Executive Board on material compliance issues and developments in an annual compliance report.
The Chief Compliance Officer works to ensure compliance with internal corporate policies by cooperating with other departments, including Group Auditing. With a view to improving cooperation within the compliance network on the European level, we organise an annual gathering of European compliance officers. Conference calls are also held in those quarters when no meeting is held. This facilitates closer coordination and supervision of the implementation of compliance measures.
A whistleblower system for the reporting of violations has been put in place. Possible topics include, among others, fraud, corruption, embezzlement, anti-competitive practices, market manipulation, breaches of insider trading regulations or avoidance of embargo provisions. The Web-based whistleblower system for companies within the Group enables employees, customers and third parties to report serious compliance violations in their local language or in English – and where permitted by law anonymously if they so wish. The whistleblower system is operated by an outside company in order to increase whistleblower protection. No technical means are available by which whistleblowers can be traced. In addition, our employees throughout the Group can seek advice on compliance matters by writing to an e-mail address associated with the Compliance Department. Any tips received as well as the measures taken in response are included in the annual compliance report.
In the year under review no notifications were received through the Group-wide whistleblower system regarding potential wrongdoing. Nor were any instances of discrimination, human rights violations or breaches of employment law or decent working conditions reported to us in the year under review. Furthermore, no lawsuits were filed against our company in the reporting period or in previous years on grounds of anti-competitive or anti-trust practices.
The Compliance Department is complemented by several Compliance Committees, the members of which come from the business groups as well as from the areas of Group Legal Services, Finance, Accounting and Investments. The Compliance Committees examine certain reinsurance contracts with a special eye to compliance with supervisory law and accounting requirements.
Our Corporate Compliance Organisational Manual is subject to continuous review. This manual summarises the main activities in the area of corporate compliance. It also describes the responsibilities within our company, the interfaces between Group Legal Services (Compliance Department) and other areas as well as the various components of the compliance organisation.
All new employees at the Hannover location take part in face-to-face compliance training when they join the company; this covers, among other aspects, the topic of corruption and appropriate practices that are in conformity with the law. In the year under review four training activities were held for altogether 107 employees. In order to stay updated on compliance issues such as combating corruption, we use traditional communication channels including intranet portals and online newsletters. Important information of company-wide relevance is made available to staff in the intranet. With effect from 2018 onwards we have also organised mandatory corporate governance training for our underwriters in property and casualty reinsurance at the Hannover location. The gives our staff an understanding of legal bases as well as internal policies and standards and provides an overview of the various in-house committees. Questions relating to general compliance matters and fighting corruption are also discussed. Altogether, some 300 employees received this training when the measure was first held. A similar training activity was held for our life and health reinsurance underwriters in August 2018. This measure will be expanded in the third quarter to include the international offices.
The Compliance Report for the 2018 calendar year was submitted to the Finance and Audit Committee in March 2019. The report describes the structure and wide-ranging activities of our company in this regard. The findings of the separate data protection reporting for the 2018 calendar year are also included in the Compliance Report. After in-depth explorations of topics such as directors' dealings, ad hoc and other notification obligations, the insider list, consultancy agreements, data privacy and international sanctions, the report concludes that only a few facts and circumstances were known that would suggest violations of compliance-related provisions. Altogether, one compliance-related incident was reported. After extensive examination of this incident the necessary precautions were taken in order to ensure for the future that we are in conformity with the internal and external requirements governing our business operations. As a consequence of the incident, we implemented a number of compliance and audit measures at the affected international office so as to improve the internal control system on the local level and at the interface between headquarters and the branch.
Our annual compliance risk analysis was carried out in the year under review in cooperation with the areas of Human Resources Management, Accounting and Taxation. As a result of this risk analysis, the possible risks of non-compliance and the steps taken to prevent non-compliance were documented and examined with an eye to their adequacy.