Our commitment to fair business
We are committed to fair and responsible business and prohibit all forms of bribery and corruption, as well as any business conduct that could create the appearance of improper influence. Our commitment to anti-bribery and anti-corruption is articulated in our Group's Code of Conduct.
Anti-bribery and anti-corruption framework
The anti-bribery and anti-corruption policy uses an implementation model which allows for a locally focused but globally conscious anti-bribery and anti-corruption mitigation program supported by appropriate and proportionate procedures.
The anti-bribery and anti-corruption policy and supporting framework are aligned with the U.S. Foreign Corrupt Practices Act (FCPA), UK Bribery Act and other cases and guidance, and prepares Zurich to meet internal and external expectations, today and in the future. The policy applies to all our employees worldwide and controls risks relating to Zurich’s ‘associated persons’ (individuals or entities who perform services for or on behalf of an organization).
Local risk assessment
The revised anti-bribery and anti-corruption framework introduces a focused local risk assessment, which targets more exposed functions and provides for the recording of effective local solutions. It continues to mitigate the risk of outgoing payments to third parties, especially to brokers, consultants and other intermediaries, for the purpose of acquiring or maintaining business.
It helps the business to identify unusual payments and implement appropriate controls. It also lays out procedures for reviewing and recording gifts, entertainment and other advantages. The policy and guidance outlines the requirements for associated persons’ due diligence before commencing the relationship and on a risk-based approach throughout the relationship.
Risk Driver Evaluation
Market facing units are required to complete a Risk Driver Evaluation to identify Inherent anti-bribery and anti-corruption risks by exposed functions. Each function within the assessment has reviewed their country of domicile and the countries that they deal with.
For this assessment the Transparency International Corruption Perception Index (TICPI) country rating scale has been used.
The anti-bribery and anti-corruption policy establishes a common framework and shared expectations for enforcement and at the same time empowers local compliance officers. Local compliance professionals make the key decisions and are accountable for adapting and applying the framework to their own business, operational, and regulatory environments. The framework includes a simple and practical local standard that provides Zurich’s employees with clear and relevant guidelines in a format and language that they can easily understand.
The policy outlines the minimum required management information including reporting key performance indicators, for example, information about a potential bribery and corruption incident and monitoring requirements for the anti-bribery and anti-corruption framework as well as expectations for reporting to boards and committees.
Speaking up and reporting concerns
We encourage employees to speak up and report conduct which they, in good faith, believe violates laws, regulations, internal processes or our Code.
We provide employees with multiple help channels, including the Zurich Ethics Line (ZEL), a Group-wide web submission and telephone hotline service, operated by an external vendor. ZEL provides a facility for employees to report concerns or seek help with business conduct issues (including anonymously where permitted by law).
Reported issues are analysed by a pre-determined triage committee which assigns investigatory responsibilities and oversees each case.
Cases in which an employee does not comply with our code of conduct or policies may constitute grounds for disciplinary action, up to and including termination of employment.