Sustainable-Development-b

Fair business practices⁸⁸

All insurers in the Sava Re Group operate in compliance with the insurance act, the companies acts and the rules prescribed by the local regulator.

All companies have adopted a code of ethics that applies to all employees. Companies have also appointed a complaints resolution officer.

In accordance with the procurement policy all purchase agreements include an anti-corruption clause as a means of insurance against this risk.

Sava Re has also signed the Slovenian Corporate Integrity Guidelines, committing the Group to creating a work environment grounded in a culture of corporate integrity, zero tolerance for the illegal and unethical conduct of its employees, compliance with legislation, rules and values as well as in the highest ethical standards. The general principles of the code of ethics represent the basic values of the Sava Re Group, which are binding on all our employees and include: fairness and compliance of business operations, transparency, managing conflicts of interests, prevention of money-laundering and financing of terrorism, and prevention of restriction of competition. Employees who are aware of violations of the code or other binding rules are obliged to report said violations to the compliance function holders. Sava Re subsidiaries have also adopted the code of ethics of the Sava Re Group.

At the end of 2017 the Company also adopted the policy on the diversity of the management and supervisory boards of Sava Re, d.d. that governs, inter alia, gender and age balance of board members. Sava Re has integrated respect for human rights in its operations in accordance with the applicable legislation and follows the proposal for the national action plan on business and human rights of the Republic of Slovenia. The Company has adopted the rules on prevention and elimination of violence, bullying, harassment and other forms of psychosocial risks in the workplace, including a protocol for recognising and resolving such risks. In 2017, the Company recorded no such cases. For the time being, the Company does notconduct due diligence investigations, but will include them among its objectives.⁸⁹

In 2017, the Company adopted new rules on the management of conflicts of interest. The management of conflicts of interest is a cornerstone of effective corporate culture, in particular of financial institutions such as Sava Re. The importance of managing conflicts of interest was further advanced by the Solvency II Directive. Previously, the Company had set out principles and guidelines on the avoidance and management of conflicts of interest in various documents, such as the code of ethics, governance policy and other specific acts. Adopting the rules on managing conflicts of interest will facilitate the implementation of the commitments the Company made in its code of ethics and of the requirements to which it is subject under the Solvency II regime. In accordance with the provisions of the Slovenian Corporate Integrity Guidelines the anti-corruption clause is incorporated in all legal relations with our contractual partners. Through restructuring that was conducted at the end of 2017 we extended the scope of work of the management board to corporate security and prevention and detection of fraud. Pursuant to Sava Re compliance policy, prevention of fraud is also one of the main responsibilities of the compliance function holder.

As a public limited company, Sava Re, d.d. regularly and upon request reports to the Insurance Supervision Agency, in accordance with the Slovenian Insurance Act (ZZavar) and implementing regulations. We also report to the Securities Market Agency in accordance with the Financial Instruments Market Act (ZTFI) and the internal rules on trading with POSR shares.

Sava Re’s reference code is the Corporate Governance Code for Listed Companies adopted by the Ljubljana Stock Exchange, the Slovenian Directors’ Association and the Managers’ Association of Slovenia on 27 October 2016.

The code of ethics of Zavarovalnica Sava, d.d. is based on trust and governs ethical and fair business conduct of the company. The code reflects and implements the principles that govern the decisions and behaviour of employees and other stakeholders. Its content and fundamental ethical principles are consistently promoted among employees and serve as a source of clear guidance in relation to legal and ethical requirements that are binding on all employees. With this code, Zavarovalnica Sava commits itself to the general principles that protect the interests of the company, respecting the dignity and integrity of each individual, protecting trade secrets, respecting clients, market rules, professionalism, avoiding conflicts of interests and concern for the environment and the wider social community.

In pursuing its business operations the company complies with the provisions of the adopted Insurance Code to ensure business development, a professional underwriting process and business conduct. The company’s operations are grounded in compliance with market principles, market competition based on loyalty and integrity, and insurance economics and business ethics, with the aim of providing customers high-quality insurance protection.

In 2017, Zavarovalnica Sava received 44 reports that were processed by the complaints resolution officer. Most of them referred to violations of the insurance code and good business practices. Only minor irregularities were identified.

In the past year they also introduced a system for recording and monitoring all significant events in the online application “Register of Continuous Improvements”. The register enables all employees to submit, by completing an online form, a report of an incident, inconsistency, deficiency or error that might refer to compliance of business operations, business processes, insurance products, risks and internal controls as well as employees and internal relationships. Employees can also submit commendations, which promotes a positive attitude across the company. In 2017, the register of continuous improvements received 25 requests. The online form does not allow for anonymous reports, because the whistle-blower protection system was not yet established in 2017.

Zavarovalnica Sava also has a system in place to manage conflicts of interest. With a written statement on disclosure of a conflict of interest (if any) employees report the conflict to their manager who examines the relevant situation, assesses the threat and reports to the compliance function holder on the proposed measures. The compliance function holder analyses all received disclosures of the conflict of interests and issues a decision imposing measures relating to the disclosure of the conflict of interests. Last year they processed 56 disclosures of conflicts of interests. Most of those disclosures referred to possible conflicts of interests in claims settlements, with regard to which only insignificant risk of conflict of interests was estimated, implying that the conflict of interest would be extremely rare. There were only a few cases where a low likelihood of occurrence of a conflict of interest was detected. Relevant measures were imposed in all discussed cases, ensuring consistent management of conflicts of interests.

In 2017 they also set up compliance standards that serve as a basis for further development of the compliance function. A regular quarterly reporting system was established for the compliance function holders to report on significant compliance activities and identified inconsistencies. No major inconsistencies were detected in 2017.⁹⁰

88: GRI 102-16, 103-1, 103-2, 103-3, 205-1, 205-3
89: GRI 405-1
90: GRI 419-1

Anti-corruption activity and protection of personal data⁹¹

In accordance with the provisions of the Slovenian Corporate Integrity Guidelines and the sourcing policy, the anti-corruption clause is incorporated as a mandatory contractual provision in legal relations with contractual partners, along with the general purchasing conditions of Zavarovalnica Sava, protection of confidential information and provisions governing the protection of personal data.

Data protection training courses were organised for all Zavarovalnica Sava employees. Throughout the year, employees were offered guidance related to the manner and importance of proper personal data protection. In 2017, a working group was set up to oversee the implementation of the new General Data Protection Regulation (Regulation (EU) 2016/679) that will take effect on 25 May 2018.

Last year they dealt with one client request for information on own personal data in accordance with the Personal Data Protection Act (ZVOP-1). They also received two complaints about alleged violations of the provisions of the act, and three requests from the Information Commissioner for submission of clarifications. Two of these procedures were concluded last year, with the reported violations recognised as unfounded.

Cases of corruption and measures taken⁹²

In Zavarovalnica Sava, insurance fraud is investigated by the investigations segment unit that is organised within the claims department. In 2017 they processed 1,161 suspected cases of insurance fraud. No payments were made in 448 of these cases.

The most common instances of insurance fraud are identified in connection with civil liability and non-life insurance products OPA. In 2017, 14 criminal charges were filed for suspected fraud.

Contributions to political parties

In line with the adopted code of ethics and the rules on sponsorship and donations Sava Re and Zavarovalnica Sava do not finance political parties.

91: GRI 103-1, 103-2, 103-3, 205-1
92: GRI 103-1, 103-2, 103-3, 205-3

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Social responsibility

Certain members of our Group are among the co-founders of the Network for Social Responsibility of Slovenia, and members of the Institute for the Development of Social Responsibility and of the Partnership for National Strategy and Social Responsibility.⁹³

Having already developed an extensive business network, Group companies can more easily recognise the needs and potentials of local communities in their respective countries. We firmly believe in co-operation, and therefore support team sports, team efforts and projects that connect organisations with their communities and that allow us to become part of social developments..

93: GRI 102-13

Sponsorships and donations⁹⁴

True to its sponsorship and donations policy Sava Re supports efforts in education and development, humanitarian, healthcare and social security initiatives, ecology, and projects that promote economic development and growth.

The value of Sava Re sponsorships and donations

(€)	2017	2016
Sponsorships	500	900
Donations	21,110	19,100

At the end of the year, Sava Re donates a part of funds allocated for business gifts to different charities. In 2017, these payments totalled €6,500.

As the largest member of the Group, present in direct business and active in two EU markets, Zavarovalnica Sava has a long-standing reputation and tradition as a socially responsible activist – also through its predecessors Zavarovalnica Maribor, Zavarovalnica Tilia, Velebit osiguranje and Velebit životno osiguranje.

The merged entity is committed to its major promise, “#Never alone”. By placing people at the centre of its operations the company promises different audiences to always be there for them – by providing for their security, through socially responsible products, friendly gestures, humanitarian campaigns, support to social efforts, an environmentally-friendly attitude and similar. Friendly communication and responsible conduct are certainly the factors that have defined the image and reputation of the new insurer.

Zavarovalnica Sava’s decisions on sponsorships and donations are dictated by the adopted rules. Donations form an integral part of its commitment to the wider community in which it operates. Through transparent donations awarded based on uniform principles and in compliance with the adopted and published Code of Ethics it demonstrates and strengthens its role of a socially responsible company.

As such it supports sports, cultural and other organisations also through its sponsorship programmes, which enable different organisations and clubs to carry out both their annual programmes and specific events. The goals and criteria measuring sponsorship performance are clearly defined. Sponsorship is viewed as a partnership that benefits both sides. Sponsorship activities constitute one of the pillars of the company’s activity and are also integral to its traditional market presence. They are therefore closely connected to the company’s operations and market presence, enhancing the brand in the environment in which it operates.

The value of Zavarovalnica Sava sponsorships and donations

(€)	2017	2016*
Sponsorships	2,141,435	2,002,612
Donations	739,594	673,786

* The information refers to Zavarovalnica Maribor, Zavarovalnica Tilia and two months of the Croatian branch taken together.

In 2017, €2.1 million was allocated for sponsorships, of which 82.9% was dedicated to sports and 17.1% to other areas.

The structure of Zavarovalnica Sava donations in 2017 by purpose

	%
Humanitarian	1.58
Cultural	11.31
Educational	3.04
Sports	70.44
Social security	0.30
Disability	0.34
Healthcare	3.14
Disaster protection	1.60
Other	8.26

Significant sponsorships and donations

Aware of the importance of a healthy lifestyle Zavarovalnica Sava dedicates most of its sponsorship funding and donations to support sports. This way it promotes sports activity at all levels, from recreation to professional sports.

For more than a decade it has been the main sponsor of Football Club Maribor, which made it into the Champions League for the third time in 2017.
The same year, Zavarovalnica Sava became the main sponsor of yet another football club, the Croatian football club Rijeka, which played in the Champions League at the same time as Maribor.
It has been the general sponsor and partner of Tennis Slovenia for five years,
and continues to sponsor Handball Club Koper and Handball Club Maribor.
As the diamond sponsor of Timing Ljubljana it takes part, for seven years running, in Slovenia’s premiere running event – the Ljubljana Marathon,

and was also, again in 2017, the main sponsor of Slovenia’s foremost skiing event under Pohorje – Zlata lisica (the Golden Fox).
By sponsoring the Nova KBM Branik Volleyball Club it contributes to the development of volleyball.
With its project Committed to Steps (Predani korakom) it provided for yet another unforgettable experience for children at the University Rehabilitation Institute, who took part in acting workshops and performed on stage at the Križanke venue in Ljubljana.
Culture lovers have benefited from its contribution as a general sponsor of the foremost Slovenian summer festival, Festival Ljubljana,
as well as from its sponsorship of Festival Lent, which the company has supported for years.

Other Group companies also actively cooperate with local communities and support them through sponsorships and donations. However, as none of them has a sponsorship and donations policy in place and since their contributions are minimal, they were not included in this report.

94: GRI 103-1, 203-1

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Preventive measures⁹⁵

Zavarovalnica Sava is paying increasing attention to preventive action.

Through timely action and adequate financial assistance the company supports organisations and associations in eliminating the causes of loss, preventing hazards that might lead to new losses for policyholders, and in eliminating or mitigating the adverse effects of losses already incurred on insured property and people.

This way, the insurance company also shows concern for the natural environment (fire prevention, prevention of pollution, traffic accidents and similar) and as a result contributes to lower expenses.

95: GRI 103-1, 103-2, 103-3

(€)	2017	2016**	2015*
Prevention	257,335	255,266	239,496

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Corporate volunteerism⁹⁷

The Sava Re Group supports corporate volunteerism. Its major volunteer project is Sava Re Day, which has been bringing together employees from all Group members for seven years running.

In collaboration with local organisations and associations we invest our efforts in helping less privileged groups and individuals in our society through intergenerational programmes and by assisting in renovations or minor repair and maintenance jobs.

In the spirit of intergenerational cooperation, Sava Re employees in 2017 went to nursing homes, occupational activity centres and similar institutions across Slovenia, where we lent a hand with landscaping efforts and renovated several children’s playgrounds, thus bringing some joy and variety to the residents’ daily routine. As many as 83% of Sava Re employees participated in the programme.

97: GRI 103-1, 413-1

In the framework of Sava Re Day 2017 Sava Re employees participated in the following volunteer activities

Organisation	Activities
Slovenian Philanthropy	Providing assistance in landscaping, maintaining and decorating the organisation’s new premises (terrace, help in making indoor furniture and preparing a hangar for the exhibition of old furniture, setting up a garden for and with the residents of the asylum centre Viè and participation at the workshop for the children of asylum seekers).
Nursing home Ljubljana Vič-Rudnik	Socialising with residents and organising bingo events.
Nursing home Logatec	Socialising with residents and walking with less mobile residents.
Nursing home Center, Tabor-Poljane	Wheelchair clean-up day.
Nursing home Fužine	Socialising with residents, making a giant Easter palm out of wood shavings and colouring Easter eggs for an exhibition.
Mothers’ shelter Ljubljana	Window painting and garden hoeing. Preparing a joint meal.
Slovenian Hospice Association	Cleaning up the premises.
Red Cross Ljubljana	Sorting out clothes to be donated to the Humanitarian Centre and preparing for the distribution of aid packages.

In addition to Sava Re Day volunteer activities Zavarovalnica Sava carried out two additional humanitarian projects with the participation of its employees:

The extremely well received “Sharing Christmas” event, an intergenerational social even, organised for the second time last year. The employees, children and residents baked gingerbread together and thus conjured up a true Christmas atmosphere at the Viè-Rudnik nursing home.

The second project, which takes place in December, is the “Christmas Dinner for All”. The aim of the project is to invite employees to donate food for the less privileged in the local communities of the insurance company’s business units. The project’s mission goes beyond the donation of food; it aims to raise awareness about poverty in our communities and the importance of caring for each other, while building relations among socially sensitive staff members.

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Sustainable development at the Sava Re Group

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SUSTAINABLE DEVELOPMENT

COMPANY

Social responsibility