The Generali Group Code of Conduct, together with our Values (Value our people, Deliver on the promise, Be open, Live the community) constitutes the foundation of the Group’s cultural identity aimed at delivering long-term success and sustainability, to contribute positively to the well-being of all stakeholders and, ultimately, to realize the purpose of enabling people to shape a safer future by caring for their lives and dreams.
Our Code sets out the behaviours that must be adopted, and provides specific guidance related, for example, to: the promotion of fair conduct of business, diversity and inclusion, sustainability, personal information and privacy, fair competition and antitrust, the prevention of conflicts of interest, bribery and corruption, money laundering, terrorist financing and international sanctions violations. It states the right to be treated fairly and without discrimination as well as to work for an organization that consistently promotes and rewards work ethics.
We guarantee the utmost confidentiality and, where permitted, we also accept anonymous reporting.
Generali Group is strongly committed to maintaining a work environment free of harassment - including sexual and non-sexual - intimidation, discrimination and retaliation for engaging in protected activities such as reporting violations or participating in an investigation pertaining to alleged violations of the law, the Code or other internal regulation.
As outlined in our Code of Conduct, the Group ensures a stimulating work environment, free of any kind of discrimination or harassment. Employees must treat one another with respect, avoiding conduct that may hurt someone else’s dignity. Managers must create and promote a welcoming and supportive environment, where integrity, respect, cooperation, diversity and inclusion are effectively pursued. This approach explicitly prohibits sexual and non-sexual harassment and has zero tolerance for discrimination. As for all the other violations of the Code, also in case of discriminatory behaviour or harassment, the defined escalation process must be followed (see above) and when it is appropriate the corrective or disciplinary actions are taken including termination of employment and may also result in civil and/or criminal sanctions, in accordance with local law and internal regulations.
The Group strictly prohibits any form of retaliatory action against employees who raise issues or ask questions, make reports, participate in an investigation, refuse to participate in suspected improper or wrongful activity. The retaliation is considered a form of misconduct. Any identified retaliation action is subject to disciplinary actions up to employment termination.
In Luxembourg, the law has appointed Commissariat aux Assurances, CAA as the Local Authority responsible for the external management of whistleblowing reports. For more information regarding the specific cases and the conditions under which the Local Authority may be contacted please refer to the CAA FAQ sections available at https://www.caa.lu/fr/whistleblowing.
Within the Group in 2022, 116 allegations were received by the Compliance Function, with the main topics broken down as follows: business conduct issues such as ethical and sustainable culture (33), discrimination, harassment and retaliation (31), internal fraud (23), conflict of interests (6), distribution (5), external fraud (5), customer relationship (4), HR administration (2), workspace security (2), bribery and corruption (1), assets and business data protection (1), personal data protection (1), marketing & advertising (1), IT system & security. In 2022, there were no allegations related to other topics beyond those listed (e.g. money laundering).
96 allegations have been closed in 2022, of which 42 substantiated leading to the adoption of the following main measures: dismissal or termination of the contract (17) and warning (16).
The monetary value of damages stemming from the above cases is considered negligible.
TRAINING ON THE CODE OF CONDUCT
- Training on discrimination and harassment in the workplace are provided with specific and local initiatives and it is covered by our trainings on the Group Code of Conduct. As of the end of 2021, 58,997 employees have completed a Code of Conduct training.