Compliance at ERV Nordic
"Compliance" means abiding by any applicable laws or corporate rules and principles.
The Compliance Management System at ERV Nordic pursues a number of aims:
- To ensure the observance of statutory and internal regulations as well as those imposed by regulatory authorities which are relevant to our business
- To avoid risks pertaining to liability, criminal punishment and to our Company´s reputation, is governing bodies (e.g. Management Board, Board of Directors) and employees, and
- To protect customers´ interests in accordance with our claim "To insure is to understand".
ERGO´s Compliance System is controlled by the local Compliance Function (Mette Skriver Have and Judith Nielsen Marchl). The Compliance Function reports directly to the Board of Management of ERV Nordic and with a dotted line to the Board of Directors of ERV Nordic as well as ERGO Compliance.
Munich RE Code of Conduct
The Munich RE Code of Conduct for all salaried employees, senior executives, members of the Boards of Management and Board of Directors of ERV Nordic provides guidance for legally impeccable behaviour based on ethical principles.
Indicate violations of laws or rules of the ERGO Code of Conduct.
If you become aware of a violation of the law or a significant breach of the rules of the Munich Re Code of Conduct, you can report this to us here.
You can also do this completely anonymously. In this case, please observe the safety instruction in the Whistleblowing Portal.
Compliance Management System
The portfolio of responsibility of ERV Nordic´s Compliance Function includes the systematic risk analysis and the continuous improvement of corporate compliance rules as well as the training and advising of colleagues and the identification of breaches.
The duties of the ERV Nordic Compliance Function include:
- Risk Assessment: Systematic identification and analysis of relevant risks;
- Early Warning: Defining and continuously improving corporate compliance rules and norms;
- Advisory: Informing, training and advising members of the Board of Management, staff and sales partners;
- Monitoring: Monitoring that regulations are adhered to and identifying breaches.
ERV Nordic´s Compliance Function caries out these tasks on behalf of Europæiske Rejseforsikring A/S including Europeiska ERV Filial. Furthermore, ERV Nordic´s Compliance Function remains in close contact with the compliance team at our parent company ERGO Group AG.
The core of the Compliance Management System is a systematic and comprehensive risk assessment, and the results create the basis for the activities of ERV Nordic´s Compliance Function.
ERV Nordic´s Compliance Function assesses the relevant risks in the individual business segments according to a uniform method and involves the respective experts and people in charge in the Company.
The risk assessment comprises the following steps:
- Development of risk scenarios
- Checks of company units or business processes in which these risks could occur
- Assessment of their possible impact and their probability
- Specifications of whether actions are required, and if so, which measures are required beyond those already in place
The risk assessment is carried out at least once each year and ad hoc where required.The ERV Nordic Board of Management is regularly notified of the results and any major changes.
Adhering to laws and regulations in Denmark and Sweden is, of course, obligatory for all employees, as well as abiding by corporate standards. It is only in this way that economical, liability and reputation risks can be avoided by ERV Nordic in the long term.
One of the most important rules is the Munich RE Code of Conduct for staff, which states our requirements for ethical behavior of employees, senior executives and management, and was last updated in 2018.
Furthermore, there are corporate rules for various topics. Example:
The Guideline on Conflict of Interests and Incentives specify the rules for tendering, planning, procuring and organizing incentives for in-house staff and sales forces.
ERGO Group AG is on ongoing basis developing successive minimum standards, which have to be implemented locally in accordance with local legislation.
All norms valid at ERV Nordic are reviewed regularly and updated where necessary and latest approved versions and further information can be found on our internal Nordic Norms Site.
Information, Training and Advice
Regular communication on compliance topics is an important part of our Compliance Management System and heightens employees´ awareness, thereby reinforcing the culture of compliance within the organisation. This is achieved through internal communication channels such as the intranet or emails, as well as regular training events. The latest updated norms are always available on our internal Nordic Norms Site.
Regular training sessions impart the compliance objectives and help in attaining standardised common understanding. Participation is mandatory for employees, senior executives and members of the Board of Management, both in-house and in sales forces.
Training includes online modules as well as face-to-face training sessions where ERV Nordic´s Compliance Function informs the entire staff or Board members and managers directly. They act as multipliers and pass on the relevant content covered in the training materials to their teams.
Our Board members and all executive employees working in-house have been training on Compliance topics in 2017. Training sessions for new employees are conducted on a quarterly basis alternating between training sessions in Denmark and Sweden.
Identifying and handling breaches
Violations of statutory provisions or Munich RE Code of Conduct (rules and internal norms are not tolerated at ERV Nordic, they are clarified and punished as appropriate). Each incident is individually assessed and sanctioned depending on the extent of the infringement. Checks are also carried out as to whether norms or processes in the Company need to be changed.
Violations are identified in a variety of ways. Apart from regular enquiries conducted among in-house staff and sales forces in Denmark and Sweden, ERV Nordic´s employees who wish to report an infringement of laws or other serious breaches can contact ERV Nordic´s Compliance Function or ERGO Compliance in confidence.
Furthermore, ERV Nordic´s Compliance Function reports on relevant events to ERGO Compliance each quarter. These include major cases of fraud and breaches of compliance, supervisory topics and major infringements of applicable rules. The reports are assessed by ERGO Compliance and then pursued by the units responsible.
Employees who do not wish to contact neither ERV Nordic´s Compliance Function nor ERGO Compliance directly can also make contact through an independent external ombudsman, who is also obliged to maintain strict confidentiality.
Violations of statutory provisions, Munich RE Code of Conduct or other internal rules are not tolerated at ERV Nordic, they are clarified and punished as appropriate.
We are convinced that the vast majority of our staff and sales agents act in an exemplary fashion. However, even the best possible set of regulations cannot stop cases of misconduct from taking place. And despite comprehensive auditing and monitoring, we will not always know all grievances with our company.
But we will follow up all evidence of misconduct which is being brought to our attention from within or outside our company. Relevant cases will be assessed individually and will be sanctioned according to the extent of the breach of the rules.