7 Corporate Governance / The 11 Best Practices

Throughout 2015, Allianz Seguros was submitted to an audit by the Group to assess its practices in ethics and governance, and obtained a very satisfactory assessment. The audit also indicated 11 best practices that could be replicated to the group.

1. Training and awareness: the company has high level of training and awareness. The area of compliance conducts monthly classroom training for various areas covering risk on several aspects (anti-corruption, anti-fraud, sales compliance, economic sanctions, data privacy, antitrust, integrity, and capital markets).

2. Performance indicators for Compliance: various indicators were established and are regularly analyzed and monitored. The indicators include: approvals for gifts and entertainment, communication with regulatory agencies, questionnaires for the Third-Party Integrity Assessment Program (PAIF).

3. Anti-corruption (sponsorship and hospitality): Allianz Seguros has in place a process to analyze and approve packages for hospitality, invitations and events.

4. Regulatory requirements: the Compliance Department manages communication received or sent to regulatory agencies aiming to monitor all official communication, as well as its content.

5. Regulatory supervision: occurs daily in order to identify any new legislation that could generate impacts for the company.

6. Anti-Corruption Due Diligence: the adoption of the evaluation process includes a thorough analysis of all third parties.

7. Compliance Self-Assessment: defined as part of the 2016 Plan. Additionally, the Compliance team verifies all Compliance programs at the company in order to identify possible improvements.

8. External reporting channel: this channel was created with the purpose of establishing an exclusive means of communication for cases that represent suspicion or occurrence of acts of corruption, including fraud, money laundering and other illicit conduct.

9. Reporting to the Compliance Department: the Compliance Department has direct communication with other areas of the company to exchange information, such as Internal Audit, Human Resources, Internal Controls, which assist in the prevention of possible deviations of conduct.

10. Anti-corruption and anti-fraud: assessment of risks of corruption, fraud and money laundering is carried out annually at Allianz Seguros and includes workshops, mapping of risks and assessment of the areas, as per guidelines of the Compliance Group and legislation in force.

11. Conflict of interest: employees are constantly being alerted about this issue. In addition, in the process to hire professionals, there is a mechanism to detect and prevent the existence of possible conflicts.