In all aspects of our business, we know the legal requirements and internal guidelines and comply with them. We have an unwavering commitment to fair and responsible business conduct and to preventing and detecting potential misuse of our products and services for illegal, criminal or unethical purposes.
Zurich is committed to fair and responsible business and takes a zero-tolerance approach to bribery and corruption and any business conduct that could create the appearance of improper influence.
We refrain from giving or accepting any gifts, entertainment or other advantages (GEOA) in connection with business activities unless they are appropriate under the circumstances, moderate in terms of value and frequency and in line with local GEOA thresholds.
We do not give, offer, or accept GEOA that are intended to, or may be perceived as being intended to, obtain or retain an improper business or personal benefit, undue action, or other favorable treatment; could cause a conflict of interest for either party; or are known or believed not to comply with applicable rules. In particular, we do not give, offer or accept cash payments or cash equivalents such as gift cards or coupons due to the risk that they could create the appearance of improper intent.
We comply with applicable laws and Zurich’s Group Policy: Anti-Bribery and Anti-Corruption so that political, charitable and similar contributions and sponsorships made by Zurich are not, and are not seen to be, used for any illegal, criminal or unethical purpose.
We also take reasonable steps so that payments to and from third parties are appropriate under the circumstances, supported by a sound business rationale, and correctly recorded and accounted for. This includes completing appropriate due diligence on third parties before engagement and taking appropriate steps to monitor their activities throughout the duration of the relationship.
A broker has offered me tickets to a local sporting event. Can I accept them? – Possibly; however, you must consider whether it would be appropriate for you to accept the invitation by assessing whether there are any ongoing negotiations involving the broker and/or whether the event could be considered unduly lavish. You may need to obtain manager approval if the value is over the local GEOA threshold and, in any event, record it appropriately in your local GEOA tool or via the applicable local process.
A supplier has invited me to a business dinner, can I accept the invitation? – Business lunches and dinners are addressed by the Anti-Bribery and Anti-Corruption Policy and if the purpose of the invitation is to maintain business relationships, it is likely acceptable. However, if the value of the dinner is above the local threshold, you must obtain manager approval and, in any event, record it appropriately in your local GEOA tool or via the applicable local process.
We are committed to applying high standards of anti-money laundering, counter-terrorist financing and tax compliance across our operations globally and do not tolerate any violations of this commitment. This includes protecting Zurich’s reputation and brand by promoting a sound culture of risk awareness, as well as disciplined and informed risk management.
Zurich does not permit engaging in transactions that are illegal or compromise our values, nor engaging in business with any person attempting to use our products or services for illegal purposes. It is never in Zurich’s interest to benefit from criminal behavior or to obtain or work with the proceeds of criminal activities.
We adhere to Group and local anti-money laundering rules and requirements and know that we should contact Compliance in a proactive and timely manner in case of any doubts or suspicions related to a business partner or transaction.
We are committed to sustainable, well-governed and transparent Group tax affairs.
To meet governmental reporting obligations which promote customer tax compliance, we have adopted policies and controls which support compliance with the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS), as well as other applicable tax regulations.
I have received a request from a customer to terminate their life insurance contract only three months after encashment of the single premium, and to issue the payment to a third party. What should I do? – You should consult with your manager and contact Compliance.
We are committed to complying with all applicable trade and economic sanctions in all our business activities.
We make sure that we are aware of laws and regulations that prohibit or restrict doing business with certain countries, entities or individuals, as well as laws and regulations that prohibit or restrict business activities with exposure to certain underlying activities that our clients may perform.
We understand applicable business processes that are in place to mitigate applicable sanctions risk of relevant activities. This includes understanding regulations that apply based on our roles and nationality, e.g., the U.S. Office of Foreign Assets Control (OFAC) regulations for U.S. persons worldwide.
I am an underwriter, and a U.S. citizen based in Europe. Do I have to follow U.S. Sanctions requirements, as the business I am working on has no U.S. exposure? – Yes, the nationality / citizenship of any U.S. employee, even if based overseas, makes the individual a ‘U.S. person’, in which case the U.S. OFAC sanctions would apply, even to a non-U.S. business. Contact Compliance for further guidance.
We firmly believe that our customers, employees, shareholders and communities are best served through a strong, competitive and fair marketplace for insurance. It is up to each of us to protect and preserve the integrity and transparency of the markets.
Any activities that impact free and fair competition could have a significant negative impact on the marketplace, our clients as well as our reputation. We do not engage in any anti-competitive practices or behaviors that are illegal or inconsistent with this Code.
Therefore, we do not enter into agreements, understandings or coordinated activities with actual or potential competitors that may eliminate or lessen free and fair competition. In particular, we do not agree or coordinate with competitors to fix prices, premiums or specific elements thereof. We do not limit or restrict the type or quantity of products or services supplied; or allocate markets geographically or according to trading partners, customers segments or product lines.
We also do not enter into agreements or arrangements with entities operating at different levels of the distribution chain, such as agents, distributors or suppliers, that may eliminate or lessen free and fair competition, in violation of applicable laws.
We do not abuse a dominant position in a particular market, nor use competitors’ confidential information without proper authorization or misuse intellectual property.
There are many situations that can create the potential for violations of antitrust and competition laws. So, if we participate in insurance associations, industry trade organizations and other meetings or events involving our competitors, we are especially mindful of all applicable laws and regulations.
A competitor’s representative suggests that Zurich sells insurance products only in certain regions of a country, whereas the competitor would sell its insurance products in other regions of the same country. Is this arrangement acceptable? – No! This is not permissible as it would violate antitrust laws prohibiting market division. The geographical allocation would hurt the insurance market in the country as Zurich and the competitor would no longer have an incentive to develop and offer better and/or more competitive products to customers in the country in order to gain a competitive advantage on each other.
As part of our day-to-day work, we may obtain inside information, which is any non-public information that could be price-sensitive, i.e., affect the price of a security. We protect inside information we possess and do not use or misuse such information whether for our own or anyone else’s investments.
We understand that we should never trade in Zurich securities or securities of other companies (either directly or through other persons) while in possession of inside information. We also do not provide tips or make recommendations about any securities while in possession of inside information.
Before trading Zurich securities, we exercise particular care and seek all necessary approvals.
Trading includes any sale, purchase, or agreement to sell or purchase any securities or interest in such securities, including if it is done off-market.
It is illegal to give false or misleading signals capable of influencing market behavior (i.e., ‘market manipulation’).
My friend is a trader. Can I give him a head start and provide him with Zurich figures before they are publicly announced? – No. You are not allowed to disclose Zurich financial results at any time before their public announcement.
We respect the protection of international human rights within our sphere of influence and will work hard to avoid being complicit in human rights abuses.
When interacting with customers, employees, shareholders, suppliers, the public at large or any other stakeholder, we aim to promote the following international best practice standards to manage potential adverse human rights impacts:
By signing the UN Global Compact in 2011, we committed to aligning our strategy, culture and day-to-day operations with the Global Compact’s ten universally accepted principles in the areas of human rights, labor, environment and anti-corruption.
We pay special attention to transactions that might contravene human rights and forced labor.
Working with suppliers
We aim to work with suppliers who share our values, and we expect high standards of ethical conduct from those who represent us or do business with us. We expect our suppliers to operate their business with integrity and using high standards of business conduct, such as the UN Global Compact or international labor standards as outlined in the International Labour Organization (ILO) conventions considered fundamental to the rights of human beings at work, as set out in our Supplier Code of Conduct.
It has come to my attention that one of our suppliers is sourcing goods from a country that is known for human rights abuses. What should I do? – You should seek advice from your local Procurement & Vendor Management team, where such a team is in place, or else from Group Procurement & Vendor Management.
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