Compliant and Ethical Business
Zurich is committed to being one of the most responsible and impactful businesses in the world. We know that we can only achieve this ambition by complying with all applicable laws, regulations and internal requirements and by living up to our values.
As an insurer, we have a crucial responsibility to our customers and society. By behaving ethically and responsibly and by standing up for what is right, we demonstrate to our customers, each other and all our stakeholders that We Care about them and that we are worthy of their trust, something that is vital for our long-term success.
Group Compliance works with business management to promote integrity and a culture of compliance and ethical conduct across the organization, and to identify and manage compliance risks.
Speaking up and reporting Integrity Concerns (Whistleblowing)
Zurich is committed to fostering a “Speak Up” culture across the organization; a culture marked by an inclusive workplace where employees feel a sense of belonging, are free to express their views and opinions without fear of retaliation, and confident that their voices will be heard.
Zurich has established multiple channels for employees to raise alleged wrongdoing or suspected or actual illegal, fraudulent, improper or unethical conduct (“Integrity Concerns”), including to people managers, Compliance, Human Resources, or Legal. Employees and others may also use the Zurich Ethics Line – Zurich’s whistleblowing system operated by an independent third-party provider – to report Integrity Concerns either via telephone or online via a web form. Reports can also be made anonymously. Zurich treats all reports of Integrity Concerns confidentially.
To report an incident of alleged wrongdoing or suspected or actual illegal, fraudulent, improper or unethical conduct, please contact our Zurich Ethics Line. For any other inquiries and general requests, including those related to claims, please click here.
In 2023, 307 reports were received globally, 84 of which were out of scope of the Integrity Concerns process. The 223 Integrity Reports received were classified under the following categories: Employee Matters (110); Financial Matters (11); Environment, Health and Safety (4); Misuse or Misappropriation of Assets or Information (32); and Policy and Process Integrity (22). The substantiation rate of reports closed in 2023 was 39%. Disciplinary actions from the substantiated reports ranged from warnings to termination.
Mandate of Group Compliance
Group Compliance is responsible for providing assurance to management that compliance risks within its mandate are appropriately identified and managed. The Group Chief Compliance Officer regularly provides reports to the Audit Committee and has an additional reporting line to the Chairman of the Audit Committee and appropriate access to the Chairman of the Board.
Group Compliance’s strategic priorities are to:
- Enable the business to manage compliance risks
- Be a trusted advisor to business management
- Provide independent challenge, monitoring and assurance for Zurich Insurance Group Ltd and its subsidiaries
Our Group Compliance Policies are reinforced by a framework that is embedded into each unit within Zurich in line with the provisions of applicable local laws and regulations. These frameworks are assessed regularly and subject to independent assurance by local Compliance teams as well as Group Internal Audit.
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Our Code of Conduct
Our Group’s Code of Conduct (our Code), which is applicable worldwide, forms the ethical foundation of our company. It outlines a set of key behaviors to guide and inspire all our employees and is built around the recognition that we must act in accordance with the highest ethical, legal and professional standards.
Our Code outlines that at Zurich, we are committed to integrity and doing the right thing; we look out for the growth and wellbeing of our people; we put our customers’ needs at the heart of all we do; we are committed to fair and responsible business conduct; we are proud of our company’s heritage and brand and protect our reputation; and we are committed to making a positive impact and driving change towards a sustainable future. We do this because at Zurich, we care.
Regardless of our rank, responsibilities or where we are located in the world, we each do our part to consider our Code and related policies as we go about our daily activities and decisions. -
Anti-Money Laundering and Counter-Terrorist Financing
At Zurich, we are committed to high standards of anti-money laundering (AML) and counter-terrorist financing (CTF). Zurich does not permit engaging in transactions that are illegal or compromise our values or engaging in business with any person attempting to use our products or services for illegal purposes.
Zurich has a dedicated Group Policy applicable to all subsidiaries and which is designed to promote compliance with applicable Money Laundering Laws.
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Trade & Economic Sanctions
Zurich is committed to adhering to all applicable trade and economic sanctions in our business activities. Our Group Policy on Trade & Economic Sanctions stipulates that all employees must be 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 Zurich’s clients may perform.
There are business processes 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.
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Anti-Bribery and Anti-Corruption
Zurich is committed to fair and responsible business and takes a zero-tolerance approach to Bribery and Corruption. Zurich prohibits all forms of Bribery and Corruption, and any business conduct that could create the appearance of improper influence and expects the same from all third parties conducting business with Zurich. Zurich maintains a global Anti-Bribery and Anti-Corruption (ABC) Framework. The framework is set forth in the ABC Group Policy (“Group Policy”).
Zurich is committed to complying fully with local and international Anti-Bribery and Anti-Corruption laws and to maintaining strong and effective compliance controls. The Group Policy is designed to help Zurich and its employees adhere to these laws including, but not limited to, the United States Foreign Corrupt Practices Act of 1977 and the United Kingdom’s Bribery Act 2010.
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Tax Compliance
Zurich considers effective and efficient tax compliance to be a key objective and allocates significant resources to promote that the tax affairs of the Group are sustainable, well governed and transparent.
In accordance with our Code, Zurich is committed to high standards of compliance. To meet governmental reporting obligations which promote customer tax compliance, Zurich has 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.
For more detailed information in relation to Zurich’s Tax Strategy, please visit: https://www.zurich.com/en/sustainability/strategy-and-governance/policies-and-frameworks/being-a-responsible-taxpayer
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Antitrust and Competition
At Zurich, we firmly believe that our customers, employees, shareholders and communities are best served through a strong, competitive and fair marketplace for insurance. Our Group Policy on Antitrust and Competition sets out our principles and our expectations for employees to avoid situations, discussions or agreements which may contravene applicable competition laws across jurisdictions. Competition laws (also known as “antitrust” or “anti-monopoly” laws) aim at ensuring that companies compete fairly.
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Conflicts of Interest
At Zurich, we know that our reputation depends on our actions and integrity. To this end, it is important that our employee’s decisions are based on the interests of our stakeholders and our company, and not based on self-interest.
Zurich has policies and procedures in place to address and manage potential conflicts of interest of its employees, agents and contractors appropriately. Where a potential, perceived or actual conflict of interest arises, disclosure and adequate and effective mitigating actions are to be implemented.
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Data Protection and Privacy
Zurich acknowledges that its responsibilities include proper compliance with data protection and privacy laws and regulations. Zurich is committed to protecting personal data and respecting privacy rights across its operations globally.
We are honoring our customers’ long-standing trust with a commitment to use data to do what is best for customers. As part of our Data Commitment, we make a promise to our customers to:
- keep their data safe;
- never sell their personal data;
- not share their personal data without being transparent about it; and
- put their data to work so Zurich can better protect them, and so they can get the most out of life.
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Customer Facing Conduct
Focus on customers is core to Zurich’s strategy and our transformation to become a truly customer-led company is well underway. We are adapting to make sure we continue to meet and exceed our customers’ expectations and needs.
Customer Facing Conduct is focused on enabling us to understand and address the potential risks associated with four main areas:- Proposition Management: We design products, services or experiences that meet the needs of our target customers
- Sales and Distribution: We sell products and services that are appropriate for our customers’ needs
- Claims and Payouts: We deliver on the promises made to our customers through the appropriate handling of claims and payouts
- Customer Service and Complaints: We provide considerate service to our customers and deal with customer complaints fairly and in a timely fashion.