Observance of applicable sanctions regulations plays a central role for us on account of our international orientation and worldwide activities. Our Code of Conduct and Underwriting Guidelines stress the obligation to comply with relevant sanctions provisions. 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 is made to continuously verify whether the company's data inventories include the names of natural and legal persons who are subject to sanctions and hence with whom no business may be transacted. Above and beyond this, each working day staff in Group Legal Services check the Official Journal of the European Union for changes in sanctions law on the EU level and advise the affected departments of relevant changes without delay.
In the year under review we pressed ahead with the roll-out of the new Sanctions Guideline. Additional branches and subsidiaries in Ireland, Sweden, Bahrain, France, Colombia and Malaysia were connected to the new system once all the employees in the accounting and underwriting departments had received appropriate training.
The compliance training given to new members of staff also includes 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.