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