Common compliance culture

Natalia Čadek (photo, © Ian Ehm)

Compliance: Illegal conduct must be prevented

Group Compliance Officer, Natalia Čadek on the special function of codes of conduct in an international group of companies.

If you look up the word “compliance” in the dictionary, you will come across terms like obedience or good behaviour. What exactly is compliance and what role does this function play in a company like VIG?

First of all, we understand it to be the observance of all existing regulations by the company and its employees – laws, regulations and voluntary commitments. Compliance as a concept also involves putting organisational measures in place in the company to ensure observance with legal norms and internal company guidelines.

What organisational measures of this type exist in VIG?

Training programmes are a very important element in this. They include not only topic-specific physical training courses, but also cross-department and cross-company workshops. Compliance also relies heavily on an exchange of information. We use an internal Group newsletter for this purpose, in which we focus on EU law. An in-depth exchange of information and experience also takes place in Compliance Committee meetings, which take place in VIG at both the holding company and Group level. Providing proactive support to employees on compliance-related issues also helps to raise awareness and create a compliance-conscious environment in the entire organisation.

What role does Compliance play in an international company and what challenges arise in connection with the CEE region in particular?

First and foremost, it is concerned with preventing unlawful conduct in the entire organisation, because such conduct can have far-reaching consequences. In addition to fines and damage claims, there is also a risk of severe damage to the company’s image and reputation. A special aspect of the compliance organisation in VIG is that it involves companies in 25 countries. This includes companies based in EU member states as well as those in third countries. In this context, the aim and key responsibility of Group Compliance is to ensure that a consistent understanding of compliance and a common compliance culture exist Group-wide. This is also the greatest challenge, particularly given the differences in legal frameworks.

Does Solvency II now provide a common compliance framework for EU member states?

Yes, that is correct. Solvency II came into force at the beginning of 2016, and imposes new, far-reaching requirements on us. Intensive preparatory work took place in the period before it came into force. The focus was primarily on designing and communicating the Group-wide compliance organisation. Now it has come into force, we have to adjust our business operations to the new regulations and make the new Solvency II regulatory regime a part of day-to-day life in our insurance company.

What are employees concerned about? Which questions do you encounter the most?

They cover a broad range, from general questions about insurance law to questions about the correct way to deal with gifts and invitations. Since VIG shares are listed, we also frequently receive questions about issuer compliance at the holding company level. In any case, what is important is that our colleagues can turn to us if they are unsure. In this way, we can further develop our compliance organisation.

This is what the local Compliance Officers have to say about the topic:

Ulrike Pruckner-Herran (illustration, © Kornel Stadler)

Ulrike Pruckner-Herran
Wiener Städtische, Austria

Project-related workshops. The compliance officers of the Austrian VIG companies meet regularly for project-related workshops to ensure an exchange of expertise between the companies. This makes synergies possible, since we often face very similar challenges.

Jaanika Ulst (illustration, © Kornel Stadler)

Jaanika Ulst
Compensa Life, Estonia

International Compliance Committee meeting. VIG compliance committee meetings are a valuable tool for cooperation. They ensure a shared understanding and an exchange of knowledge. The Group-wide compliance structure and regular communication are an important source of support for the local compliance departments.

Tomasz Gradkowski (illustration, © Kornel Stadler)

Tomasz Gradkowski
Compensa Life & Non-Life, Poland

Local meetings. At the formal level, information is exchanged within the Group by means of periodic and ad hoc reports. At the same time, however, it is just as important to meet regularly in person to exchange views and experiences.

Martin Laur (illustration, © Kornel Stadler)

Martin Laur
Kooperativa CZ, Czech Republic

Newsletter. Regular and successful cooperation is the basis for our teamwork within the Group. Many compliance issues are solved jointly. We especially value the VIG compliance newsletter. It provides helpful information, particularly on current initiatives at the European level.