VIVAT has taken fundamental steps in entering into business relationships with pension clients. Business partners who want to purchase their pension from VIVAT are tested on the basis of a comprehensive list of sustainability criteria (ESG points). The outcome is decisive for concluding and / or extending performance contracts. To keep the execution controlled and careful, we will implement this policy step-by-step. After evaluating the acceptance policy within pensions, we will extend this acceptance policy to the non-life insurance policies of VIVAT.
Responsible Insurance: Customer Due Diligence
Services to customers may imply that VIVAT NV and underlying entities are exposed to the risk of doing business with unethical relationships and / or committing an economic offense. By adhering to the customer integrity policy and the compliance with Sanctions Regulations, VIVAT wants to prevent VIVAT or parts of VIVAT from acting carelessly or culpably in money laundering transactions, terrorist financing, fraud and / or other risky non-integer or norm-transgressing behaviour. Customer due diligence (CDD) forms part of the obligations insurers have in the field of sound business operations. VIVAT accepts new customers with the required care and strives for the best possible knowledge of the customer. In doing so, we examine who the customer is, what activities they carry out, who the ultimate stakeholders are within a legal entity and whether the customer or ultimate stakeholder constitutes a (reputational) risk for VIVAT.
VIVAT wants its activities to comply with laws and regulations and its internal standards. With this in mind, VIVAT will:
- Take all reasonable measures to only have customers in good standing;
- Take all reasonable measures to discover cases where it is being abused for money laundering or terrorist financing;
- Take all reasonable measures to cooperate with competent governmental authorities to implement anti-money laundering and terrorist financing laws.
The customer is not accepted in the following cases:
- If the customer survey does not lead to identification, verification and determination of the purpose and the intended nature of the relationship and / or if the customer is not willing to provide the necessary information;
- Sanction regulations apply to the customer (Sanctions Act);
- Branches and customers who do not act in accordance with generally accepted and ethical principles:
- Human rights violations;
- Social issues (including child labor, forced labor and international labor rights);
- Serious violations of the environment;
- Forms of corruption;
- The production of or trade in (controversial) weapons.
- A customer who is associated with ‘negative’ publicity;
- If there are indicators that the customer is involved in money laundering and / or terrorist financing.
The objective of the Policy Compliance with Sanctions Regulations is that VIVAT complies at all times with the Sanctions Regulations. Relationships are monitored against the sanctions lists of the EU, the UN and Dutch sanction lists. This screening of relations takes place upon acceptance, periodically and / or with changes to the customer base and changes to the sanction lists. VIVAT also uses filtering along the OFAC list in addition to its legal obligation. In case of a modification of the sanction lists or the OFAC list, all existing relations are screened.
Some relationships, by their nature, pose a higher risk of money laundering or terrorist financing. In order to compensate for this higher risk, additional measures are taken by applying stricter customer research. Countries with a higher risk of money laundering and terrorist financing are qualified as increased risk countries. When countries have been identified by the FATF as countries that have insufficiently set up a money laundering and terrorist financing system, this is seen as one of the factors that increases the risk of money laundering and terrorist financing of a relationship or transaction. Customers who are resident or established in these countries are at increased risk. Part of the CDD policy is testing whether the customer or ultimate interested party qualifies as a Politically Exposed Person (PEP). This refers to persons who hold or have held a prominent public function and the immediate family members or close associates of these persons. Business relationships with and provision of services to PEPs require additional measures because they increase the chances of reputational damage and other risks, including money laundering. In addition, provision of services to PEPs requires special attention in the context of international policy on combating corruption. All customers are automatically checked against a PEP list on acceptance and periodically.